October 30, 2018 Gregory Boden Chief Financial Officer CLOUDCOMMERCE, INC. 1933 Cliff Drive, Suite 1 Santa Barbara, CA 93109 Re: CLOUDCOMMERCE, INC. Form 10-K for the Transition Period From July 1, 2017 to December 31, 2017 Filed April 13, 2018 Form 8-K Filed August 2, 2017 Form 8-K Filed November 17, 2017 File No. 000-13215 Dear Mr. Boden: We have reviewed your filing 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 8-K Filed November 17, 2017 Item 9,01 Financial Statements and Exhibits, page 3 1. Please tell us if you plan to amend to include financial statements and pro forma financial information required by Item 9.01(a) and (b) of Form 8-K. In addition, please show us your significance tests. Refer to Rule 8-04 of Regulation S-X. Gregory Boden CLOUDCOMMERCE, INC. October 30, 2018 Page 2 Form 8-K Filed August 2, 2017 Item 9.01 Financial Statements and Exhibits, page 6 2. Please tell us when you plan to file the audited abbreviated statements of assets acquired and liabilities assumed and of revenues and direct expenses for the acquisition of Parscale Creative, Inc. as indicated in your letter to the Division of Corporation's Office of the Chief Accountant dated August 14, 2017. 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 Adam Phippen, Staff Accountant, at (202) 551-3336 or William Thompson, Accounting Branch Chief, at (202) 551-3344 with any questions. Sincerely, FirstName LastNameGregory Boden Division of Corporation Finance Comapany NameCLOUDCOMMERCE, INC. Office of Consumer Products October 30, 2018 Page 2 cc: Andrew Van Noy FirstName LastName