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                              December 14, 2022

       Davinder Singh
       Chief Financial Officer
       Tucows Inc.
       96 Mowat Avenue
       Toronto, Ontario M6K 3M1
       Canada

                                                        Re: Tucows Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Form 10-Q for the
Fiscal Year Ended September 30, 2022
                                                            File No. 001-32600

       Dear Davinder Singh:

              We have reviewed your filings 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 10-K for the Fiscal Year Ended December 31, 2021

       Consolidated Statements of Cash Flows, page F-8

   1.                                                   Tell us how you account
for the gain on the sale of Ting customer assets in your
                                                        consolidated statement
of cash flows. Refer us to your basis in the accounting literature.

       Form 10-Q for the Fiscal Quarters Ended September 30, 2022

       Notes to Consolidated Financial Statements
       13. Segment Reporting, page 17

   2.                                                   For each reportable
segment, please show revenue from external customers and
                                                        intersegment revenue in
accordance with ASC 280-10-50-32. Provide us with your
                                                        proposed future
presentation.
 Davinder Singh
Tucows Inc.
December 14, 2022
Page 2
3.       It appears that you consider segment adjusted EBITDA to be a measure
of segment
         operating profit or loss. If so, please remove all references to this
measure as a non-
         GAAP measure when presented within your segment footnote. Please also
move the
         reconciliation of total Adjusted EBITDA so that it is presented after
the presentation of
         segment Adjusted EBITDA. See Item 10(e)(1)(ii)(c) of Regulation S-K
and Question
         104.04 of our non-GAAP Compliance & Disclosure Interpretations. Please
revise
         accordingly in future filings.
4.       Please reconcile segment gross margin to net income (loss) before
income taxes in
         accordance with ASC 280-10-50-30 to 32. Your reconciliation should
identify and
         describe all significant reconciling items, including but not limited
to elimination of
         intersegment revenue. Provide us with your proposed future
presentation.
Adjusted EBITDA, page 43

5.       Please reconcile your Non-GAAP measure adjusted EBITDA from Net
Income. We refer
         to Questions 103.02 and 102.10(b) of the Compliance & Disclosure
Interpretations on
         Non-GAAP Financial Measures. We note a similar reconciliation in
Exhibit 99.1 of your
         Form 8-K filed on November 7, 2022. Provide us with your proposed
future presentation.

6.       We note that you use adjusted EBITDA to evaluate the operational and
financial
         performance of your core business. Tell us if the gain from the sale
of your assets to
         DISH is included in Adjusted EBITDA. If these gains are included in
Adjusted EBITDA,
         tell how this measure allows investors to evaluate the operational and
financial
         performance of your core business.
Liquidity and Capital Resources, page F-44

7.       Enhance your liquidity discussion to analyze your ability to generate
and obtain adequate
         amounts of cash to meet your requirements and your plans for cash in
the short-term and
         separately in the long-term. We refer you to the guidance in Item 303
of Regulation S-K.
        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 Inessa Kessman, Senior Staff Accountant, at 202-557-3371
or Lisa
Etheredge, Senior Staff Accountant, at 202-551-3424 if you have any questions.



FirstName LastNameDavinder Singh                                Sincerely,
Comapany NameTucows Inc.
                                                                Division of
Corporation Finance
December 14, 2022 Page 2                                        Office of
Technology
FirstName LastName