United States securities and exchange commission logo January 21, 2021 Rory Cutaia Chief Executive Officer Verb Technology Company, Inc. 782 South Auto Mall Drive American Fork, UT 84003 Re: Verb Technology Company, Inc. Registration Statement on Form S-3 Filed January 15, 2021 File No. 333-252167 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 Nicholas Lamparski at (202) 551-4695 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Larry A. Cerutti