United States securities and exchange commission logo December 17, 2020 Paul Roberts Interim Chief Executive Officer Kubient, Inc. 228 Park Avenue South Suite 72602 New York, NY 10003 Re: Kubient, Inc. Draft Registration Statement on Form S-1 Submitted December 17, 2020 CIK No. 0001729750 Dear Mr. Roberts: This is to advise you that we do not intend to review your registration statement. We request that you publicly file your registration statement no later than 48 hours prior to the requested effective date and time. Please refer to Rule 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 Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you require further assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815. Sincerely, Division of Corporation Finance Office of Technology cc: Marc J. Adesso