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                              December 8, 2021

       Jose Antonio de Souza Azevedo
       Chief Financial Officer
       Atento S.A.
       1, rue Hildegard Von Bingen
       L-1282, Luxembourg
       Grand Duchy of Luxenbourg

                                                        Re: Atento S.A.
                                                            Form 20-F for the
year ended December 31, 2020
                                                            File No. 001-36671

       Dear Mr. de Souza Azevedo:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 20-F for the year ended December 31, 2020

       Notes to the Consolidated Financial Statements
       Note 22 - Revenue and Expenses, page F-62

   1.                                                   Please revise to
describe the nature of the various services or performance obligations you
                                                        offer in contracts with
customers. Also address the timing of revenue recognition and
                                                        typical payment terms
and how that relates to the satisfaction of the performance
                                                        obligations. Finally,
if you offer contracts with multiple performance obligations, address
                                                        how you allocate the
transaction price. Refer to guidance in IFRS 15.
       Note 23 - Segment Information, page F-66

   2.                                                   You state that the CODM
uses EBITDA and Adjusted EBITDA to measure the segment's
                                                        operating performance;
however, you appear to present only EBITDA. Please explain
                                                        your reference to
Adjusted EBITDA here. Also, tell us why you include segment
                                                        operating profit and
segment profit for the year in the tabular disclosures. In this regard,
 Jose Antonio de Souza Azevedo
Atento S.A.
December 8, 2021
Page 2
      if the CODM uses more than one measure of a segment's profit or loss, the
reported
      (single) measure shall be the one that management believes is determined
in accordance
      with the measurement principles most consistent with those used in
measuring the
      corresponding amount in your consolidated financial statements. Please
tell us your
      consideration to disclose only one measure of segment profit or loss.
Refer to IFRS 8.26.
      Lastly, revise to reconcile the total of your reportable segments'
measure of profit or loss
      to the entity's profit or loss pursuant to IFRS 8.28(b).
3.    We will consider further your response to the previous comment and the
impact it may
      have on your disclosures in the forepart of the filing. In this regard,
you present various
      segment measures in the table on page 56 and elsewhere throughout the
filing, such as
      segment operating profit/(loss), profit/(loss) for the year, EBITDA and
Adjusted EBITDA,
      some of which may be considered non-IFRS measures.
       In closing, 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.

       You may contact Brittany Ebbertt, Senior Staff Accountant, at
202-551-3572 or
Kathleen Collins, Accounting Branch Chief, at 202-551-3499 with any questions.



                                                            Sincerely,
FirstName LastNameJose Antonio de Souza Azevedo
                                                            Division of
Corporation Finance
Comapany NameAtento S.A.
                                                            Office of
Technology
December 8, 2021 Page 2
cc:       Virginia Beltramini Trapero
FirstName LastName