July 16, 2018

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-1
           Filed June 25, 2018
           File No. 333-225876

Dear Mr. Mills:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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

Security Ownership of Certain Beneficial Owners and Management, page 39

1.     Please identify the natural person or persons who directly or indirectly
exercise sole or
       shared voting and/or dispositive power with respect to the shares
beneficially owned by
       Slipstream Funding, LLC, Slipstream Communications, LLC and Horton
Capital Partners
       Fund, L.P., or tell us why you do not believe this disclosure is
required. See Item 507 of
       Regulation S-K. For additional guidance, refer to Question 140.02 of
Regulation S-K
       Compliance and Disclosure Interpretations.
 Richard Mills
Creative Realities, Inc.
July 16, 2018
Page 2
General

2.     Please disclose your related party transactions pursuant to Item 404 of
Regulation S-K. In
       this regard, you state on page 8 that you have a "significant related
party customer."
       We also note that your principal shareholder is affiliated with David
Bell, a director of the
       company.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Michael Foland, Attorney-Advisor, at (202) 551-6711 or
Jan Woo,
Legal Branch Chief, at (202) 551-3453 with any other questions.



FirstName LastNameRichard Mills                              Division of
Corporation Finance
                                                             Office of
Information Technologies
Comapany NameCreative Realities, Inc.
                                                             and Services
July 16, 2018 Page 2
cc:       Paul Chestovich
FirstName LastName