United States securities and exchange commission logo October 27, 2020 Rory Cutaia Chief Executive Officer Verb Technology Company, Inc. 2210 Newport Boulevard, Suite 200 Newport Beach, California 92663 Re: Verb Technology Company, Inc. Registration Statement on Form S-3 Filed October 20, 2020 File No. 333-249564 Dear Mr. Cutaia: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Daniel Morris at (202) 551-3314 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Larry Cerutti, Esq.