November 15, 2018

Gregory Boden
Chief Financial Officer
CLOUDCOMMERCE, INC.
1933 Cliff Drive, Suite 1
Santa Barbara, CA 93109

       Re: CLOUDCOMMERCE, INC.
           Form 8-K Filed November 17, 2017
           Response Dated November 9, 2018
           File No. 000-13215

Dear Mr. Boden:

       We have reviewed your November 9, 2018 response to our comment letter
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. Unless we note otherwise, our references to prior comments are to
comments in our
October 30, 2018 letter.

Form 8-K Filed November 17, 2017

Item 9.01 Financial Statements and Exhibits, page 6

1.    We reviewed your response to comment 1. In measuring significance, you
used financial
      information as of and for the period ended December 31, 2017. Pursuant to
Rule 8-04(b)
      of Regulation S-X, significance tests should be measured using financial
information from
      the most recently completed fiscal year prior to the acquisition.
Further, we note that you
      used your total stockholders' equity when performing the income test. The
income test
      requires you to compare your equity in the income from continuing
operations before
      income taxes of the acquiree exclusive of amounts attributable to any
noncontrolling
      interests to such consolidated income of yourself for the most recently
completed fiscal
 Gregory Boden
CLOUDCOMMERCE, INC.
November 15, 2018
Page 2
      year prior to the acquisition. Refer to Rule 8-04(b)(3) of Regulation
S-X. Please provide
      us with revised significance tests. Finally, please tell us your
consideration of Rule 8-
      04(d) of Regulation S-X when calculating significance in light of the
August 1, 2017
      acquisition of Parscale Creative, Inc.
     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
November 15, 2018 Page 2
cc:       Andrew Van Noy
FirstName LastName