United States securities and exchange commission logo May 21, 2020 Richard Mills Chief Executive Officer Creative Realities, Inc. 13100 Magisterial Drive, Suite 100 Louisville, KY 40223 Re: Creative Realities, Inc. Registration Statement on Form S-3 Filed May 15, 2020 File No. 333-238275 Dear Mr. Mills: 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 Matthew Derby, Staff Attorney, at (202) 551-3334 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Bradley Pederson