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                             May 18, 2022

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

                                                        Re: Bubblr Inc.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed May 4, 2022
                                                            File No. 333-262680

       Dear Mr. Willard:

             We have reviewed your amended registration statement 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 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.
Unless we note
       otherwise, our references to prior comments are to comments in our April
22, 2022 letter.

       Amendment No. 2 to Form S-1

       Cover Page

   1.                                                   In response to prior
comment 2, you disclose that the Selling Stockholders may sell their
                                                        shares of common stock
underlying the Series C Preferred and Warrants at a fixed price of
                                                        $0.40 per share or, if
quoted on the OTCQB, at prevailing market prices, prices related to
                                                        prevailing market
prices or at privately negotiated prices. Please include the shares being
                                                        offered by White Lion
Capital, LLC in this pricing disclosure on the prospectus cover
                                                        page and in the Plan of
Distribution.
 Rik Willard
FirstName
Bubblr Inc.LastNameRik Willard
Comapany
May        NameBubblr Inc.
     18, 2022
May 18,
Page 2 2022 Page 2
FirstName LastName
2.       In response to prior comment 4, you revised your disclosure throughout
the prospectus to
         state that the company may submit puts under the Equity Financing
Agreement until the
         earlier of December, 31, 2022 or until $15 million worth of shares
have been the subject
         of a purchase notice. As noted in prior comment 4, this is
inconsistent with the terms of
         the Equity Financing Agreement. Please revise your disclosure to
reflect the terms of the
         agreement.
Executive Compensation
Management Compensation, page 33

3.       You disclose that on April 20, 2022, your board of directors approved
the amended and
         restated employment agreements for your Chief Executive Officer and
Chief Commercial
         Officer. Please file these employments agreements as exhibits and file
an Item 5.02 Form
         8-K.
Exhibits

4.       Please revise the legality opinion to reflect that the opinion relates
to the resale by the
         selling stockholders of a total of 13,385,595 shares. In addition,
please update the exhibit
         index to hyperlink to the updated legality opinion.
       Please contact Kathleen Krebs, Special Counsel, at 202-551-3350 or
Joshua Shainess,
Legal Branch Chief, at 202-551-7951 with any other questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Technology
cc:      Scott Doney, Esq.