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                             July 22, 2020

       Joshua Harley
       Chief Executive Officer
       Fathom Holdings Inc.
       211 New Edition Court, Suite 211
       Cary, NC 27511

                                                        Re: Fathom Holdings
Inc.
                                                            Amendment No. 4 to
                                                            Registration
Statement on Form S-1
                                                            Filed July 16, 2020
                                                            File No. 333-235972

       Dear Mr. Harley:

             We have reviewed your amended registration statement and have the
following
       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.
Unless we note
       otherwise, our references to prior comments are to comments in our July
15, 2020 letter.

       Amendment 4 to Form S-1 filed July 16, 2020

       General

   1.                                                   We note your response
to comment 1 and that you paid RISMedia for the cover article. It
                                                        appears that you cannot
rely on Rule 433(f). Please tell us how you believe you met the
                                                        filing and delivery
conditions in Securities Act Rule 433(b)(2)(i) with respect to the July
                                                        1, 2020 FWP, given that
the prospectus you had on file did not appear to meet the
                                                        requirements of Section
10 of the Securities Act because it did not contain a price range.
                                                        For guidance, see
Securities Act Rules Compliance and Disclosure Interpretations
                                                        Question 232.05.
 Joshua Harley
Fathom Holdings Inc.
July 22, 2020
Page 2
Management's Discussion and Analysis of Financial Position and Results of
Operations
COVID-19, page 34

2.       We note from your response to prior comment 2 that you have concluded
that there is no
         further information or metrics that would be helpful to investors at
this time. We also note
         your disclosure indicates that according to the National Association
of Realtors, the
         coronavirus is leading to fewer home buyers, as well as listings being
delayed. Please tell
         us if you have experienced any negative effects on transaction volume
and other relevant
         metrics. Please tell us what consideration you gave to disclosing
transaction volume
         subsequent to March 31, 2020.
        You may contact William Demarest at 202-551-3432 or Jennifer Monick at
202-551-
3295 if you have questions regarding comments on the financial statements and
related
matters. Please contact Jonathan Burr at 202-551-5833 or James Lopez at
202-551-3536 with
any other questions.



FirstName LastNameJoshua Harley                               Sincerely,
Comapany NameFathom Holdings Inc.
                                                              Division of
Corporation Finance
July 22, 2020 Page 2                                          Office of Real
Estate & Construction
FirstName LastName