August 21, 2019

Reinier Voigt
Chief Executive Officer
Cool Holdings, Inc.
2001 NW 84th Avenue
Miami, FL 33122

       Re: Cool Holdings, Inc.
           Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A
           Filed August 19, 2019
           File No. 001-32217

Dear Mr. Voigt:

       We have limited our review of your filing to the issue addressed in our
comment.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A

General

1.    Please expand your response to prior comment 1 to tell us:

          the sources of all funds required to complete the Simply Mac
transaction; include the
          amount of funds available from each source;
          whether proceeds you received when you issued the securities that are
the subject of
          proposal 3 were intended for the Simply Mac transaction or will be
used for the
          Simply Mac transaction;
          whether the proceeds from the exercise of the warrants to be modified
or issued if
          proposal 3 is approved can be used for the Simply Mac transaction or
to reduce the
          amount that you may be required to use under the commitment letter;
          where you have filed the commitment letter, and provide us your
analysis of whether
          you must describe the letter in your proxy statement for investors to
have the
          information required to make a voting decision; and
 Reinier Voigt
Cool Holdings, Inc.
August 21, 2019
Page 2

          whether there are any prohibitions on your use the authority sought
by proposal 4 for
          (1) funding the Simply Mac transaction, (2) conversion of the notes
or issuance of the
          warrants that were the subject of the proposals that you removed, (3)
repayment of
          amounts received under the commitment letter, or (4) reduction of the
amount needed
          to be drawn under the commitment letter.

      Also, given your responses to the above and your statement regarding the
Simply Mac
      transaction on page 20, please clarify the basis for your conclusion that
the proposals do
      not involve the Simply Mac transaction as contemplated by Note A to
Schedule 14A. Cite
      in your response all authority on which you rely.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

      Please contact Geoff Kruczek, Special Counsel, at (202) 551-3641 or
Russell Mancuso,
Branch Chief, at (202) 551-3617 with any other questions.



                                                           Sincerely,
FirstName LastNameReinier Voigt
                                                           Division of
Corporation Finance
Comapany NameCool Holdings, Inc.
                                                           Office of
Electronics and Machinery
August 21, 2019 Page 2
cc:       James Guttman
FirstName LastName