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                               June 23, 2020

       Rory Cutaia
       Chief Executive Officer
       Verb Technology Company, Inc.
       2210 Newport Boulevard, Suite 200
       Newport Beach, California 92663

                                                        Re: Verb Technology
Company, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed June 9, 2020
                                                            File No. 333-239055

       Dear Mr. Cutaia:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comment. In our comment, we may ask you to provide us
with information so
       we may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this comment, we may have additional comments.

       Registration Statement on Form S-1

       Choice of Forum, page 90

   1.                                                   We note that your forum
selection provision identifies "courts located within the State of
                                                        Nevada" as the
exclusive forum for certain litigation, including any "derivative action."
                                                        Please revise to
clarify whether "courts located within the State of Nevada" includes both
                                                        state and federal
courts, and whether the provision applies to claims made under the
                                                        federal securities
laws. In that regard, we note that Section 27 of the Exchange Act
                                                        creates exclusive
federal jurisdiction over all suits brought to enforce any duty or liability
                                                        created by the Exchange
Act or the rules and regulations thereunder, and Section 22 of the
                                                        Securities Act creates
concurrent jurisdiction for federal and state courts over all suits
                                                        brought to enforce any
duty or liability created by the Securities Act or the rules and
                                                        regulations thereunder.
If the provision applies to claims made under the federal securities
 Rory Cutaia
Verb Technology Company, Inc.
June 23, 2020
Page 2
      laws, please revise to include disclosure regarding the risks or other
impacts of the
      provision on investors, including but not limited to increased costs to
bring a claim and
      the potential discouraging of claims or limitation of investors' ability
to bring claims in
      judicial forums that they find favorable. Further, if the provision
applies to Securities Act
      claims, please also revise your registration statement to state that
there is uncertainty as to
      whether a court would enforce such provision and that investors cannot
waive compliance
      with the federal securities laws and the rules and regulations
thereunder. If this provision
      does not apply to actions arising under the Securities Act or Exchange
Act, please also
      ensure that the exclusive forum provision in the governing documents
states this clearly,
      or tell us how you will inform investors in future filings that the
provision does not apply
      to any actions arising under the Securities Act or Exchange Act.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Cara Wirth at (202) 551-7127 or Lilyanna Peyser at (202)
551-3222 with
any questions.



                                                              Sincerely,
FirstName LastNameRory Cutaia
                                                              Division of
Corporation Finance
Comapany NameVerb Technology Company, Inc.
                                                              Office of Trade &
Services
June 23, 2020 Page 2
cc:       Larry Cerutti, Esq.
FirstName LastName