SecProbe.io

Via fax (801) 847-6422
       October 19, 2010

Paul G. Begum
Chairman & CEO
Klever Marketing, Inc.
2469 E Ft Union Blvd No. 214 Cottonw ood, UT 84121

Re: Klever Marketing, Inc.
 Form 10-K & Form 10-K/A for the Fi scal Year Ended December 31, 2009
 Filed April 13, 2010 and Ap ril 30, 2010, respectively
 Form 10-Q & Form 10-Q/A for th e Quarter Ended June 30, 2010
 Filed August 13, 2010 and August 17, 2010, respectively
File No. 000-18730

Dear Mr. Begum:
We have reviewed your filings 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 within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.

Form 10-K and 10-K/A for the Year Ended December 31, 2009

Item 9.  Controls and Procedures, page 12

1. It does not appear that your management has performed its assessment of internal control
over financial reporting as of December 31, 2009.  Since you were required to file or filed an annual report for the prior fiscal year, it appears you ar e required to report on your
management’s assessment of internal control over financial reporting.  If your
management has not yet performed its assessment, we ask that you complete your evaluation and amend your filing within 30 calendar days to provide the required
management's report on internal control ove r financial reporting.  In performing your
evaluation, you may find the following documents helpful:

 Paul G. Begum
Klever Marketing, Inc. October 19, 2010 Page 2
ƒ the Commission’s release Amendments to Rules Regarding Management’s Report on
Internal Control Over Financial Reporting  (Securities Act Release 8809/Financial
Reporting Release 76).  You can find this release at:
http://www.sec.gov/rules/final/2007/33-8809.pdf
;
ƒ the Commission’s release Commission Guidance Regarding  Management’s Report on
Internal Control Over Financial Reporti ng Under Section 13(a ) or 15(d) of the
Securities Exchange Act of 1934 (Securities Act Releas e 8010/Financial Reporting
Release 77).  You can find this release at http://sec.gov/rule s/interp/2007/33-
8810.pdf ; and
ƒ the “Sarbanes-Oxley Section 404 – A Guid e for Small Business” brochure at:
(http://www.sec.gov/info/smallbus/404guide.shtml ).
 Please note that the failure to perform ma nagement’s assessment adversely affects the
company’s and its shareholders ability to av ail themselves of rules and forms that are
predicated on the current or timely filing of Exchange Act reports.  For further information regarding these impacts, please see Compliance and Disclosure Interpretation
115.02, which you can find at http://www.sec.gov/divisions /corpfin/guidance/regs-
kinterp.htm .
 2. Please consider whether management’s failu re to perform or complete its report on
internal control over financial reporting impacts its conclusions regarding the effectiveness of your disclosure controls and pr ocedures as of the end of the fiscal year
covered by the report and revise your disclosure as appropriate.
 3. Notwithstanding your response to comment  2 above, please explain further how
management concluded your disclosure cont rols and procedures were effective at
December 31, 2009 considering the factors th at led management to conclude your
disclosure controls and procedures were  ineffective at March 31, 2010 and June 30, 2010
appear to have also existed at December 31, 2009.
 4. We note your CEO concluded that your disc losure controls and procedures were
“effective in timely alerting him to material information relating to the Company required to be included in the reports that the Comp any files and submits pur suant to the Exchange
Act.”  Please revise to clarify, if true, that your officers concluded your disclosure controls and procedures are effective to en sure that the information required to be
disclosed by the company in reports that it  files under the Exchange Act is recorded,
processed, summarized and reported within  the time periods specified in the
Commission’s rules and forms and also to ensure that information required to be
disclosed in the reports that you file or submit under the Exchange Act is accumulated
and communicated to management, as appropria te, to allow timely decisions regarding
required disclosure.  In this regard, please note that if your conclusions concerning the
effectiveness of your disclosure controls and procedures refer to the definition of
disclosure controls and procedur es as indicated in Rule 15(e) of the Exchange Act, then

 Paul G. Begum
Klever Marketing, Inc. October 19, 2010 Page 3
you should either (1) provide the entire defi nition or (2) clearly indicate that the
evaluation was made with respect to disclosu re controls and proce dures as defined in
Rule 13a-15(e) of the Exchange Act.  Please revise your filings accordingly.
 Exhibits 31.1 and 31.2

 5. We note that you filed your Principal Executiv e Officer and Principal Financial Officer
certifications under Item 601(b)(3 1) of Regulation S- K. Please revise these certifications
to include the introductory language of paragraph 4 of Item 601(b )(31) of Regulation S-
K.  Similar revisions should be made to your March 31, 2010 and June 30, 2010 Forms 10-Q.

Form 10-Q and Form 10-Q/A for the Quarter Ended June 30, 2010

Item 4(T). Controls a nd Procedures, page 13

Management’s Report on Internal Control over Financial Reporting, page 13
 6. Please explain further your disclosure s in both the March 31, 2010 and June 30, 2010
Forms 10-Q with regards to management’s report on internal control over financial
reporting.  In this regard, tell us if you actually performed an evaluation of your internal controls over financial re porting at each of these dates.  If so, tell us why and specifically
address how you considered the requirements of Item 308T(a) of Regulation S-K to assess the effectiveness of the company’s inte rnal control over fina ncial reporting as of
the end of your most recent fiscal year.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of  the United States.

 Paul G. Begum Klever Marketing, Inc. October 19, 2010 Page 4
You may contact Megan Akst, Staff Accountant at (202) 551 -3407 if you have questions
regarding comments on the financ ial statements and related ma tters.  If you need further
assistance, you may cont act me at (202) 551-3499.

Sincerely,

Kathleen Collins Accounting Branch Chief