October 22, 2019

Patrick White
Chief Executive Officer
VerifyMe, Inc.
75 S. Clinton Ave., Suite 510
Rochester, NY 14604

       Re: VerifyMe, Inc.
           Registration Statement on Form S-1
           Filed October 10, 2019
           File No. 333-234155

Dear Mr. White:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-1

Cover Page

1.     Please revise your prospectus prior to effectiveness to disclose the
number of units, shares
       and warrants to be offered. For guidance, please refer to Securities Act
Rules Compliance
       and Disclosure Interpretations Question 227.02.
General

2.     Please include disclosure indicating the method by which your offering
price will be
       determined. See Item 501(b)(3) 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
 Patrick White
VerifyMe, Inc.
October 22, 2019
Page 2

action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Ada D. Sarmento at 202-551-3798 or Celeste Murphy at
202-551-3257
with any questions.



                                                           Sincerely,
FirstName LastNamePatrick White
                                                           Division of
Corporation Finance
Comapany NameVerifyMe, Inc.
                                                           Office of Life
Sciences
October 22, 2019 Page 2
cc:       Alexander R. McClean, Esq.
FirstName LastName