September 28,
2018

Richard Mills
Chief Executive Officer
Creative Realities, Inc.
13100 Magisterial Drive, Suite 100
Louisville, KY 40223

       Re: Creative Realities, Inc.
           Amendment No. 2 to Registration Statement on Form S-1
           Filed September 21, 2018
           File No. 333-225876

Dear Mr. Mills:

      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.

Amendment No. 2 to Form S-1

Prospectus Summary, page 1

1.     Please clarify whether the closing of this offering is a condition to
the acquisition of
       Allure Global Solutions, Inc. If so, include disclosure that the
acquisition may not occur
       if you are not approved for listing on The NASDAQ Capital Market, which
is a condition
       of this offering.
Signatures, page II-7

2.     Instruction 1 to Signatures of Form S-1 requires signatures of your
principal executive
       officer or officers, your principal financial officer, your controller
or principal accounting
 Richard Mills
Creative Realities, Inc.
September 28, 2018
Page 2
       officer and at least a majority of the board of directors or persons
performing similar
       functions. To the extent that you are signing in more than one capacity,
indicate each
       capacity in which you are signing. Please revise.
       You may contact Michael Foland, Attorney-Advisor, at (202) 551-6711 or
Jan Woo,
Legal Branch Chief, (202) 551-3453 with any other questions.



                                                             Sincerely,

FirstName LastNameRichard Mills                              Division of
Corporation Finance
                                                             Office of
Information Technologies
Comapany NameCreative Realities, Inc.
                                                             and Services
September 28, 2018 Page 2
cc:       Paul Chestovich
FirstName LastName