UNITED STATES

                             SECURITIES AND EXCHANGE COMMISSION
                                         WASHINGTON, D.C. 20549



     DIVISION OF
CORPORATION FINANCE



                                                              March 27, 2019

Jeremy Hodara
Co-Chief Executive Officer
Jumia Technologies AG
CharlottenstraBe 4
10969 Berlin, Germany

         Re: Jumia Technologies AG
             Registration Statement on Form F-1
             Filed March 12, 2019
             File No. 333-230207

Dear Mr. Hodara:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.

Form F-1 filed March 12, 2019

Selected Consolidated Financial and Operating Data
Selected Other Data, page 76

1.      We note you added a non-GAAP financial measure, Platform contribution,
which you
        define as gross profit, less non-platform revenue, less direct
fulfillment expense (freight
        and shipping), which is expense related to the services of third party
logistics providers.
        You state that direct fulfillment expense corresponds to [the line
item] fulfillment expense
        less "other fulfillment expense" which you define as fulfillment
expense mainly related to
        your network of warehouses, including employee benefit expenses. It
appears that certain
        of your fulfillment expenses excluded to arrive at the non-GAAP
performance measure
        Platform contribution may represent normal, recurring, cash operating
expenses and also
        that Platform contribution may represent a tailored performance
measure. We note you
 Jeremy Hodara
Jumia Technologies AG
March 27, 2019
Page 2
       present and/or discuss Platform contribution throughout your
registration statement on
       pages 76, 77, 80, 81, 85, 90 and 99. Please tell us how you considered
the guidance in
       Questions 100.0land 100.04 of the Compliance and Disclosure
Interpretations on Non
       GAAP Financial Measures, effective April 4, 2018 available on our
website at
       https://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm in
presenting this non
       GAAP measure. In your response please tell us the specific nature of all
costs included in
       each of direct fulfillment expense and other fulfillment expense and
whether such costs
       are normal, recurring, cash operating expenses, non-cash expenses or
some other type of
       non-recurnng expense.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies and Judgments, page 87

2.     We note your response to comment 6. In order to assist us in
understanding and
       evaluating your response, please provide the following information:

           Please tell us the number of equity interests utilized at each of
May 1, 2018 and
           December 1, 2018 to derive the corresponding fair value per equity
interest used in
           determining your stock compensation in the disclosures presented in
Note 13 on pages
           F-32 to F-33, based on your estimates of the fair value of Jumia KG
at each of those
           dates. Please provide your computations in your response.
           Per your response the disclosures and amounts presented in Note 13
related to the
           number of stock options and participations granted on the May 1,
2018 and December
           1, 2018 grant dates do not reflect the roll up and conversion of
stock options
           subsequent to the conversion of Africa Internet Holding GmbH into
Jumia
           Technologies AG. Please supplementally provide us with the impact or
anticipated
           impact of those events on your outstanding share options including
the impact on the
           number of options granted, the number of options outstanding and the
exercise
           price(s).
           Lastly, please reconcile the fair values per equity interest at each
of May 1, 2018 and
           December 1, 2018 to the mid-point of the estimated IPO price range
per share and
           ADS. We may have further comment after reviewing your response.
Signatures, page 11-4

3.     Please include the signature of your principal accounting officer or
controller. If Mr.
       Maillet-Mezeray is your principal accounting officer or controller,
please include the
       appropriate title in his signature block. Refer to Form F-1.
        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.
 Jeremy Hodara
Jumia Technologies AG
March 27, 2019
Page 3

       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.

        You may contact, Sondra Snyder, Staff Accountant at 202-551-3332 or Jim
Allegretto,
Senior Assistant Chief Accountant at 202-551-3849 if you have questions
regarding comments
on the financial statements and related matters. Please contact Scott Anderegg,
Staff Attorney at
202-551-3342 or Lilyanna Peyser, Special Counsel at 202-551-3342 with any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Consumer
Products
cc:    Krystian Czemiecki