United States securities and exchange commission logo November 5, 2020 Arik Maimon Chief Executive Officer Cuentas Inc. 19 W. Flagler Street, Suite 902 Miami, FL 33130 Re: Cuentas Inc. Registration Statement on Form S-1 Filed October 28, 2020 File No. 333-249690 Dear Mr. Maimon: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 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 Scott Anderegg at 202-551-3342 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services