August 23, 2019

Barry D. Loveless
Chief Financial Officer
SPYR, Inc.
4643 S. Ulster Street, Suite 1510
Denver, Colorado 80237

       Re: SPYR, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed April 1, 2019
           File No. 033-20111

Dear Mr. Loveless:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018

Controls and Procedures, page 47

1.     Please amend this section to separately distinguish between your
evaluation of disclosure
       controls and procedures and that of internal control over financial
reporting. In this
       regard, it does not appear you have separately reported on and concluded
on
       management's evaluation of internal control over financial reporting.
Given that your
       disclosure controls and procedures were concluded as being not effective
due to the
       material weaknesses identified, we would anticipate similar conclusion
would be reached
       for internal control over financial reporting for the same reasons.
Please amend and
       expand your disclosures to comply with the requirements of Item 308(a)
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
 Barry D. Loveless
SPYR, Inc.
August 23, 2019
Page 2

action by the staff.

       You may contact Beverly Singleton at (202) 551-3328 or Melissa Raminpour
at (202)
551-3379 if you have questions regarding comments on the financial statements
and related
matters.



FirstName LastNameBarry D. Loveless                      Sincerely,
Comapany NameSPYR, Inc.
                                                         Division of
Corporation Finance
August 23, 2019 Page 2                                   Office of
Transportation and Leisure
FirstName LastName