September 24,
2018

Ryan Perfit
Chief Financial Officer
Fluent, Inc.
33 Whitehall Street, 15th Floor
New York, NY 10004

       Re: Fluent, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 14, 2018
           Form 10-Q for the Fiscal Quarter Ended June 30, 2018
           Filed August 8, 2018
           File No. 001-37893

Dear Mr. Perfit:

       We have limited our review of your filing to the financial statements
and related
disclosures 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, 2017

Summary of significant accounting policies
(h) Goodwill, page F-14

1.     We note goodwill represents a substantial element of your Balance Sheet.
You
       disclose that the results of your impairment testing indicated the fair
value of your
       reporting units exceeded their carrying amount. We note that your
Information Services
       reporting unit has historically incurred substantial losses from
operations. Please modify
       your disclosure to state, if true, that the results of your impairment
testing indicate the fair
       values of each reporting unit substantially exceed their carrying
values. Otherwise, please
       disclose (either here or within Critical Accounting Policies in MD&A)
the amount or
 Ryan Perfit
Fluent, Inc.
September 24, 2018
Page 2
         percentage by which each reporting unit's fair value exceeds its
carrying value.
Form 10-Q for the Fiscal Quarter Ended June 30, 2018

Summary of significant accounting policies
(c) Revenue recognition, page 7

2.       You disclose on page 8 that you have a right to payment from customers
in an amount that
         corresponds directly with the value of the performance completed to
date. We note that a
         significant portion of your accounts receivable as of June 30, 2018
and December 31,
         2017 consists of unbilled revenue. Please expand your revenue policy
to describe the
         circumstances that result in delays between revenue recognition and
the issuance of
         customer invoices. Please tell us the extent to which your unbilled
revenue balances as of
         June 30, 2018 have been subsequently invoiced and how long it took to
issue those
         invoices.
       In closing, 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.

       You may contact Joseph Cascarano, Staff Accountant, at (202) 551-337or
Lisa Haynes
Etheredge, Staff Accountant, at (202) 551-3424 with any questions.



FirstName LastNameRyan Perfit                                  Sincerely,
Comapany NameFluent, Inc.
                                                               Division of
Corporation Finance
September 24, 2018 Page 2                                      Office of
Telecommunications
FirstName LastName