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                            April 22, 2022

       Rik Willard
       Chief Executive Officer
       Bubblr Inc.
       21 West 46th Street
       New York, NY 10036

                                                        Re: Bubblr Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed April 8, 2022
                                                            File No. 333-262680

       Dear Mr. Willard:

              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.

       Amendment No. 1 to Form S-1

       Cover Page

   1.                                                   You disclose that GHS
Investments, LLC and Proactive Capital Partners LP are offering
                                                        for resale    up to
6,000,000 shares of Common Stock issuable upon conversion of the
                                                        Company   s Series C
Preferred Stock (   Series C Preferred   ) and Warrants that these selling
                                                        shareholders may
acquire pursuant to the terms and conditions of Securities Purchase
                                                        Agreements that we
entered into with GHS and Proactive (the    Purchase Agreement   ), as
                                                        well as Warrants to
purchase Common Stock.    Please clarify what is being registered.
                                                        For example, disclose
how many shares are issuable upon conversion of the Series C
                                                        Preferred Stock and how
many shares are issuable upon exercise of the Warrants. Explain
                                                        to us how you arrived
at these numbers. Also explain whether you are registering shares
                                                        underlying Series C
Preferred Stock or Warrants that have not yet been issued. In this
 Rik Willard
FirstName
Bubblr Inc.LastNameRik Willard
Comapany
April       NameBubblr Inc.
       22, 2022
April 222, 2022 Page 2
Page
FirstName LastName
         regard, we note that only the Initial Closing under the Securities
Purchase Agreement with
         GHS had occurred prior to the filing of the amended registration
statement, and additional
         closings for three more tranches are contemplated. Lastly, clarify
whether your reference
         to    as well as Warrants to purchase Common Stock    means that you
are registering any
         Warrants for resale.
2.       You disclose that    [t]he price at which the Selling Stockholders may
sell their shares will
         be at a fixed price of $0.40 per share or, if we are quoted on the
OTCQB, at prevailing
         market prices, prices related to prevailing market prices or at
privately negotiated prices.
         Clarify whether this applies to the resale of the shares GHS will
receive under the Equity
         Financing Agreement.
3.       Please disclose here that GHS Investments, LLC is an underwriter. For
guidance, refer to
         Securities Act Compliance and Disclosure Interpretation 139.13.
4.       Please correct your disclosure indicating that the company may submit
puts under the
         Equity Financing Agreement through December 31, 2022 or until $15.0
million in shares
         have been the subject of a Purchase Notice. In this regard, the Equity
Financing
         Agreement and disclosure elsewhere in the prospectus indicate that
puts may be delivered
         until 24 months after effectiveness of the registration statement or
the date on which GHS
         has purchased an aggregate of $15.0 million worth of common stock. In
addition, clarify
         under "The Offering" section on page 4 whether you intend for the
offering to terminate
         on the earlier of the sale of all the shares being registered or
December 31, 2022.
Equity Financing Agreement and Registration Rights Agreement with GHS, page 2

5.       You disclose throughout the prospectus that the Equity Financing
Agreement with GHS
         was entered into on March 4, 2022. The Equity Financing Agreement
filed as Exhibit
         10.8 indicates the agreement is dated March 9, 2022. Please reconcile
these dates.
Selling Stockholders, page 21

6.       Please revise the table to list each selling stockholder separately.
For shares beneficially
         owned by a selling stockholder that are not currently outstanding,
provide footnote
         disclosure that details the number of shares beneficially owned and
being offered upon
         conversion of Series C Preferred Stock, upon exercise of warrants and
pursuant to the
         Equity Financing Agreement, as applicable.
Plan of Distribution, page 40

7.       Please revise your plan of distribution to be consistent with the
disclosure on the
         prospectus cover page regarding the securities being registered and
how and at what price
         they will be sold.
8.       Please disclose any short selling of the company   s securities or
other hedging activities
         that GHS may or has engaged in, including prior to entering into the
Equity Financing
         Agreement and prior to the receipt of any shares pursuant to the terms
of the agreement.
 Rik Willard
Bubblr Inc.
April 22, 2022
Page 3
9.    Please clarify how the provisions of Regulation M may prohibit GHS and
any other
      participants in the distribution of the company   s securities from:
          engaging in market making activities (e.g., placing bids or making
purchases
           to stabilize the price of the common stock) while the equity line is
in effect; and
          purchasing shares in the open market while the equity line is in
effect.
Exhibits

10.   Please revise the exhibit index to provide more detailed information
about each exhibit so
      that investors may more easily identify what has been filed as an
exhibit. For example,
      where appropriate, identify the parties to and dates of the agreements.
In this regard, you
      list three exhibits as    Employment Agreement,    two exhibits as
Common Stock Purchase
      Warrants    and two exhibits as    Securities Purchase Agreement.
These are just examples.
11.   In addition, please file all material portions of the agreements. For
example, the Securities
      Purchase Agreements filed as Exhibit 10.6 and 10.7 do not contain the
signature pages of
      the counterparties. Without these signatures pages, there is no
indication who the
      counterparties are or the subscription amount.
12.   Please file an updated legality opinion that opines on the shares being
registered in the
      revised offering.
        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 Kathleen Krebs, Special Counsel, at 202-551-3350 or
Joshua Shainess,
Legal Branch Chief, at 202-551-7951 with any questions.



                                                             Sincerely,
FirstName LastNameRik Willard
                                                             Division of
Corporation Finance
Comapany NameBubblr Inc.
                                                             Office of
Technology
April 22, 2022 Page 3
cc:       Scott Doney, Esq.
FirstName LastName