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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 letter dated November 3, 2010 in connection with the above-referenced
filings and have the following comment.  In our comment, we may ask you to provide us with
information so we may better understand your disclosure.
 Please respond to this letter within ten busin ess days by amending your filing, by providing the
requested information, or by advising us when you will provide the requested response.  If you do not believe our comment applies to your facts and ci rcumstances 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
this comment, we may have additional comments.  Unless otherwise noted, where prior comments are
referred to they refer to our  letter dated October 19, 2010.
 Form 10-K and 10-K/A for the Year Ended December 31, 2009

Item 9.  Controls and Procedures, page 12

1. We note your responses to prior comments 1-4 and the proposed revise d disclosures that you
intend to include in your Form 10-K/A when filed.  With regards to such disclosures, we have the following additional comments:

• Please explain further your discussion under “Evaluation of Disclosure Controls and
Procedures” as it relates to the Audit Committee.  For instance, if your intent is to explain
what actions management is taking to addre ss the material weakness noted, then please
clarify your disclosures to indicate as such;

Paul G. Begum Klever Marketing, Inc. November 10, 2010 Page 2
• Revise the first sentence in your discussion of  “Internal Control Over Financial Reporting”
to indicate that management is responsible  for establishing and maintaining adequate
internal controls over financial reporting
 for the company;
• Revise your reference to “United States ge nerally accepted accounting principles (GAAP)”
for internal control over financial reporting to instead refer to the standards of the Public
Company Accounting Oversight Board (United St ates) for internal control over financial
reporting;
• Explain further your disclosures indicating that  you “have not achieved the desired level of
documentation of [your] internal controls and pr ocedures.”  If your in tent was to disclose
your lack of documentation as a material wea kness, then please include this disclosure
along with your discussion of th e other material weakness; and
• You indicate that there were “no other  changes made in [your]  internal controls over
financial reporting…”  However, you have not  included a discussion of any changes that
have been made to your internal controls  over financial reporti ng and therefore, your
reference to “other changes” is confusing.  Pl ease explain the intent of your disclosure and
as applicable, revise to include  a discussion of all changes to  your internal controls over
financial reporting and/or remove the refere nce “other changes” in your disclosures.

Please provide a draft copy of your proposed disclosures that address these issues.
 Exhibits 31.1 and 31.2

 2. We note your response to prior comment 5; how ever it appears that you misunderstood the
portion of the certifica tions to which we were referri ng.  The introductory language of
paragraph 4 should refer to the officer’s responsib ility over disclosure co ntrols and procedures
as well as internal controls ove r financial reporting. In this rega rd, paragraph 4 should read as
follows:  “The registrant's other certifying offi cer(s) and I are responsible for establishing and
maintaining disclosure controls and procedures  (as defined in Excha nge Act Rules 13a-15(e)
and 15d-15(e)) and internal control over financial repor ting (as defined in Exchange Act Rules
13a-15(f) and 15d-15(f)) for the registrant and have:”  We refer you to Item 601(b)(31) of
Regulation S-K.  Please amend your Form 10-K acco rdingly.  In addition, 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 and Procedures

Management’s Report on Internal Control over Financial Reporting, page 13

3. Your response to prior comment 6 indicates that your CEO preformed an evaluation of the
company’s internal control over financial reporting at each of the two quarters ending March 31, 2010 and June 30, 2010.  Please confirm that ma nagement conducted an evaluation of your
internal controls over financial reporting at each of these date s at the level required by Item
308T(a) even though such an evaluation is only requi red on an annual basis.  If so, please also

 Paul G. Begum Klever Marketing, Inc. November 10, 2010 Page 3
confirm that you have maintained evidential  matter, including documentation, to provide
reasonable support for management’s assessment of th e effectiveness of the registrant’s internal
control over financial reporting at each
 of these dates.  To the exte nt that you did not perform a
full evaluation of your internal controls over financial reporting at March 31, 2010 and June 30,
2010, then revise to remove the discussion of such an evaluation in your Forms 10-Q and limit
your discussion to the disclosure required by Item 308T(b) for changes in internal control over
financial reporting during the quarter.

You may contact Megan Akst, Staff Accountant at (202) 551 -3407 if you have questions
regarding comments on the financial statements and related matters.  If you need further assistance,
you may contact me at (202) 551-3499.
Sincerely,

Kathleen Collins Accounting Branch Chief