TEXT-EXTRACT 2 filename2.txt September 3, 2019 Kevin Brian Cox Chief Executive Officer Surge Holdings, Inc. 3124 Brother Blvd 104 Bartlett, TN 38133 Re: Surge Holdings, Inc. Form 10-Q for the Quarterly Period Ended March 31, 2019 Filed May 15, 2019 Form 10-K for the Fiscal Year Ended December 31, 2018 Filed April 1, 2019 File No. 000-52522 Dear Mr. Cox: We have completed our review of your filings. 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. Sincerely, Division of Corporation Finance Office of Telecommunications