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                 November 17, 2022

       Darren Marks
       Chief Executive Officer
       Grom Social Enterprises, Inc.
       2060 NW Boca Raton Blvd., #6
       Boca Raton, Florida 33431

                                                        Re: Grom Social
Enterprises, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed November 9,
2022
                                                            File No. 333-268278

       Dear Darren Marks:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

              Please refer to Rule 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 Alexandra Barone, Staff Attorney, at (202) 551-8816
or Jan Woo, Legal
       Branch Chief, at (202) 551-3453 with any questions.




                 Sincerely,


                 Division of Corporation Finance

                 Office of Technology
       cc:                                              Joseph Lucosky