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                               December 21, 2022

       Massimo Barone
       Chief Executive Officer
       SmartCard Marketing Systems Inc.
       20C Trolley Square
       Wilmington, DE 19806

                                                        Re: SmartCard Marketing
Systems Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed December 16,
2022
                                                            File No. 333-268839

       Dear Massimo Barone:

              We have reviewed your registration statement and have the
following comment. In our
       comment, 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 comment applies 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 filed December 16, 2022

       Exhibits

   1.                                                   Please file as Exhibit
23.1 a consent for your independent registered public accounting
                                                        firm. In this regard,
we note you have filed the auditor report as Exhibit 23.1 instead of a
                                                        consent.
               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.

              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.
 Massimo Barone
SmartCard Marketing Systems Inc.
December 21, 2022
Page 2

       You may contact Patrick Kuhn at 202-551-3308 or Joel Parker at
202-551-3651 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071
with any other
questions.



                                                         Sincerely,
FirstName LastNameMassimo Barone
                                                         Division of
Corporation Finance
Comapany NameSmartCard Marketing Systems Inc.
                                                         Office of Trade &
Services
December 21, 2022 Page 2
cc:       Evan Costaldo, Esq.
FirstName LastName