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                              August 10, 2020

       Peter Anthony Bordes, Jr.
       Chief Executive Officer
       Kubient, Inc.
       330 Seventh Avenue, 10th Floor
       New York, NY 10011

                                                        Re: Kubient, Inc.
                                                            Amendment No. 4 to
Registration Statement on Form S-1
                                                            Filed August 10,
2020
                                                            File No. 333-239682

       Dear Mr. Bordes, Jr.:

             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.

       Form S-1/A filed August 10, 2020

       Management's Discussion and Analysis of Financial Condition and Results
of Operation
       Overview, page 37

   1.                                                   It appears based upon
the carrying value of the Notes and accrued interest the Notes will
                                                        convert at a
significant discount to the public offering price per unit. Please disclose the
                                                        actual percentage
discount, how you will account for the conversions, and the charge that
                                                        will be incurred as a
result.
 Peter Anthony Bordes, Jr.
FirstName  LastNamePeter Anthony Bordes, Jr.
Kubient, Inc.
Comapany
August  10, NameKubient,
            2020          Inc.
August
Page  2 10, 2020 Page 2
FirstName LastName
Financial Statements
Note 1 - Business Organization, Nature of Operations, Risks and Uncertainties
and Basis of
Presentation
Unaudited Pro Forma Information, page F-5

2.       Disclose the actual percentage discount to the mid-point of the
estimated offering price
         range the will result from converting the balance of the Notes and
accrued interest
         liabilities into an aggregate of 1,174,281 units. Also disclose the
charge that will be
         incurred upon conversion and give pro forma effect to it in the
accumulated deficit
         balance.
Exhibits

3.       Please update your legality opinion to reflect the change in the
number of units being
         offered.
        You may contact Lisa Etheredge, Staff Accountant, at (202) 551-3424 or
Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Matthew Crispino,
Staff Attorney, at (202) 551-3456 or Larry Spirgel, Office Chief, at (202)
551-3815 with any
other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
cc:      Marc J. Adesso