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                     April 28, 2022

       Srikumar Vanamali
       Chief Executive Officer
       GEX Management, Inc.
       662 W. Camp Wisdom Road
       Dallas, Texas 75237

                                                        Re: GEX Management,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed April 15,
2021
                                                            Amendment No. 3 to
Form 10-K for the Fiscal Year Ended December 31, 2020
                                                            Filed February 11,
2022
                                                            Amendment No 1.Form
10-Q for the Period Ended June 30, 2021
                                                            Filed February 8,
2022
                                                            File No. 001-38288

       Dear Mr. Vanamali:

              We have reviewed your March 8, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       December 2, 2021 letter.
 Srikumar Vanamali
FirstName   LastNameSrikumar Vanamali
GEX Management,     Inc.
Comapany
April       NameGEX Management, Inc.
       28, 2022
April 228, 2022 Page 2
Page
FirstName LastName
Amendment No 1.Form 10-Q for the Period Ended June 30, 2021

Notes to the Condensed Consolidated Financial Statements, page 8

1.       We note your response to our prior comment number 3. It is not clear
why the obligations
         for your "merchant cash advances" that are material to you and in
default are not
         discussed in the notes to your financial statements in all periodic
filings until they are
         either satisfied or no longer considered material in your
circumstances. It appears
         disclosure in the notes to the financial statements commensurate with
your response, along
         with all material terms and conditions, including any associated
defaults and related
         consequences and status of settlement discussions, would be useful
information to
         investors and support associated amounts reported in your financial
statements. Please
         advise and revise as appropriate.
Amendment No. 3 to Form 10-K for the Fiscal Year Ended December 31, 2020

Item 9A. Controls and Procedures
Conclusions Related to Internal Control over Financial Reporting, page 12

2.       You have revised your disclosure in this section to repeat your
conclusion regarding the
         effectiveness of your disclosure controls and procedures rather than
disclose your
         conclusion in regard to your internal controls over financial
reporting. Please note that a
         conclusion regarding the effectiveness of your internal controls over
financial reporting is
         required by Item 308(a)(3) of Regulation S-K apart from a conclusion
regarding
         disclosure controls and procedures required by Item 307 of Regulation
S-K. Please revise
         as appropriate.
       You may contact Aamira Chaudhry at 202-551-3389 or Doug Jones at
202-551-3309 if
you have questions regarding comments on the financial statements and related
matters.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services