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December 14, 2022
Davinder Singh
Chief Financial Officer
Tucows Inc.
96 Mowat Avenue
Toronto, Ontario M6K 3M1
Canada
Re:Tucows Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Form 10-Q for the Fiscal Year Ended September 30, 2022
File No. 001-32600
Dear Davinder Singh:
            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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Consolidated Statements of Cash Flows, page F-8
1.Tell us how you account for the gain on the sale of Ting customer assets in your
consolidated statement of cash flows.  Refer us to your basis in the accounting literature.

Form 10-Q for the Fiscal Quarters Ended September 30, 2022
Notes to Consolidated Financial Statements
13. Segment Reporting, page 17
2.For each reportable segment, please show revenue from external customers and
intersegment revenue in accordance with ASC 280-10-50-32.  Provide us with your
proposed future presentation.

 FirstName LastNameDavinder Singh
 Comapany NameTucows Inc.
 December 14, 2022 Page 2
 FirstName LastName
Davinder Singh
Tucows Inc.
December 14, 2022
Page 2
3.It appears that you consider segment adjusted EBITDA to be a measure of segment
operating profit or loss.  If so, please remove all references to this measure as a non-
GAAP measure when presented within your segment footnote.  Please also move the
reconciliation of total Adjusted EBITDA so that it is presented after the presentation of
segment Adjusted EBITDA.  See Item 10(e)(1)(ii)(c) of Regulation S-K and Question
104.04 of our non-GAAP Compliance & Disclosure Interpretations.  Please revise
accordingly in future filings.
4.Please reconcile segment gross margin to net income (loss) before income taxes in
accordance with ASC 280-10-50-30 to 32.  Your reconciliation should identify and
describe all significant reconciling items, including but not limited to elimination of
intersegment revenue.  Provide us with your proposed future presentation.
Adjusted EBITDA, page 43
5.Please reconcile your Non-GAAP measure adjusted EBITDA from Net Income.  We refer
to Questions 103.02 and 102.10(b) of the Compliance & Disclosure Interpretations on
Non-GAAP Financial Measures.  We note a similar reconciliation in Exhibit 99.1 of your
Form 8-K filed on November 7, 2022.  Provide us with your proposed future presentation.

6.We note that you use adjusted EBITDA to evaluate the operational and financial
performance of your core business.  Tell us if the gain from the sale of your assets to
DISH is included in Adjusted EBITDA.  If these gains are included in Adjusted EBITDA,
tell how this measure allows investors to evaluate the operational and financial
performance of your core business.
Liquidity and Capital Resources, page F-44
7.Enhance your liquidity discussion to analyze your ability to generate and obtain adequate
amounts of cash to meet your requirements and your plans for cash in the short-term and
separately in the long-term.  We refer you to the guidance in Item 303 of Regulation S-K.
            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.
            You may contact Inessa Kessman, Senior Staff Accountant, at 202-557-3371 or Lisa
Etheredge, Senior Staff Accountant, at 202-551-3424 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology