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Cheap Stock Letter

 Jon Gavenman

 +1 650 843 5055

jgavenman@cooley.com

 *FOIA Confidential Treatment Request*

Confidential Treatment Requested by Sonim Technologies, Inc. in

connection with Registration Statement on Form S-1 filed on
April 15, 2019

 April 23, 2019

 U.S.
Securities and Exchange Commission

 Division of Corporation Finance

100 F Street, N.E.

 Washington D.C. 20549

Attn:
 Joshua Shainess

Celeste M. Murphy

 Kathryn
Jacobson

 Lisa Etheredge

RE:
 Sonim Technologies, Inc.

Registration Statement on Form S-1

Filed on April 15, 2019

File No. 333-230887

Ladies and Gentlemen:

 On behalf of Sonim Technologies, Inc.
(the “Company”), we are supplementally providing the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with information regarding the
proposed price range of the shares of the Company’s common stock to be offered in the proposed initial public offering (“IPO”) pursuant to the Company’s Registration Statement on
Form S-1 (File No. 333-230887), as filed with the Commission on April 15, 2019 (the “Registration Statement”), as well as
historical information with respect to the estimated fair value of its common stock since April 1, 2018. We are providing this letter in response to the comment from the Staff received by letter dated April 3, 2019 (the “Comment
Letter”) relating to the Registration Statement originally confidentially submitted on February 14, 2019.

 Confidential Treatment
Request

 Due to the commercially sensitive nature of information contained in this letter, the Company hereby requests, pursuant to 17 C.F.R.
§200.83, that certain portions of this letter be maintained in confidence, not be made part of any public record and not be disclosed to any person. The Company has filed a separate copy of this letter, marked to show the portions redacted from
the version filed via EDGAR and for which the Company is requesting confidential treatment. In accordance with 17 C.F.R. §200.83(d)(1), if any person (including any governmental employee who is not an employee of the Commission) should request
access to or an opportunity to inspect this letter, we request that we be immediately notified of any such request, be furnished with a copy of all written materials pertaining to such request (including, but not limited to, the request itself) and
be given at least ten business days’ advance notice of any intended release so that the Company may, if it deems it to be necessary or appropriate, pursue any remedies available to it. In such event, we request that you telephone the
undersigned at 650-843-5055 rather than rely on the U.S. mail for such notice.

[*]
 Certain confidential information contained in this letter, marked by brackets, has been omitted and filed
separately with the Commission pursuant to 17 C.F.R. §200.83.

 Cooley LLP 3175 Hanover Street Palo Alto, CA
94304-1130

 t: (650) 843-5000 f: (650) 849-7400 cooley.com

 Page Two

 For the convenience of the Staff, we have recited the prior comment from the Comment Letter from the Staff in
italicized type and have followed the comment with the Company’s response.

 15. You disclose on page F-41
that between November 2018 and January 2019, you sold 1,498,533 shares of common stock to accredited investors for $7.18 per share. We also note your disclosure on page 79 that certain officers were granted stock options in September 2018 at an
exercise price of $0.90 per share. Once you have an estimated offering price or range, please explain to us how you determined the fair value of the common stock underlying all equity related issuances during the last twelve months and the reasons
for any differences between the recent valuations of your common stock leading up to the IPO and the estimated offering price. This information will help facilitate our review of your accounting for equity issuances including stock compensation.

 IPO Price Range

 The Company supplementally
advises the Staff that the Company preliminarily estimates a price range of $[***] to $[***] per share (the “IPO Price Range”) for its IPO. As is typical in IPOs, the IPO Price Range was not derived using a
formal determination of fair value, but was determined by discussions between the Company and the underwriters. The IPO Price Range has been estimated based, in part, upon current market conditions, the Company’s financial condition and
prospects, performance of recent initial public offerings and input received from the lead underwriters. In determining the IPO Price Range, the underwriters focused on a number of valuation methodologies to triangulate the valuation, including a
discounted cash flow analysis and relevant trading multiples.

 Historical Fair Value Determination and Methodology

As stated in the Registration Statement, the Company accounts for stock-based compensation expense related to stock-based awards based on the estimated fair
value of the award on the grant date, net of estimated forfeitures. For stock-based awards subject to performance conditions, the Company evaluates the probability of achieving each performance condition at each reporting date and recognizes expense
when it is deemed probable that a performance condition will be met using the accelerated attribution method. The Registration Statement describes the Company’s use of the Black-Scholes option-pricing model for the purpose of calculating the
fair value of stock options and describes and quantifies the significant assumptions used.

 The board of directors of the Company (the
“Board”) intended all options granted to be exercisable at a price per share not less than the per share fair value of the common stock underlying those options on the date of grant. Historically, the estimated fair values of
the shares of the Company’s common stock underlying the Company’s stock options were estimated on each grant date by the Board and were supported by periodic independent third-party valuations. In contrast to the metrics used by the
underwriters in determining the IPO Price Range, the historical valuations of the Company’s common stock were determined by an independent third-party valuation firm in accordance with the guidance provided by the American Institute of
Certified Public Accountants Practice Guide, Valuation of Privately-Held-Company Equity Securities Issued as Compensation as described herein and starting on page 60 of the Registration Statement. As described below, since April 1, 2018,
the Company made equity awards in September 2018 (the “September 2018 Grants”) based in part on an independent third-party valuation as of August 31, 2018 (the “August Valuation”) and in April
2019 (the “April 2019 Grants” and, together with the September 2018 Grants, the “Grants”) based in part on an independent third-party valuation as of March 31, 2019 (the “March
Valuation” and, together with the August Valuation, the “Valuations”).

[*]
 Certain confidential information contained in this letter, marked by brackets, has been omitted and filed
separately with the Commission pursuant to 17 C.F.R. §200.83.

 Cooley LLP 3175 Hanover Street Palo Alto, CA
94304-1130

 t: (650) 843-5000 f: (650) 849-7400 cooley.com

 Page Three

The methodology used by the Company and the third-party valuation firm to determine the fair value of the Company’s common stock in the August Valuation included a weighting of the market
approach based on comparable public company revenue multiples and the income approach based on the discounted cash flows (“DCF”) method, with the portion of total equity value allocated to the Company’s common stock
estimated using the Option Pricing Method (“OPM”), as further discussed below under “Determination of Estimated Value.” The Board determined that there were no material changes in the Company’s business since
August 2018 or in the assumptions upon which the August Valuation was based that had affected the fair value of its shares of common stock at the time of the September 2018 Grants. The methodology used by the Company and the third-party valuation
firm to determine the fair value of the Company’s common stock in the March Valuation included a weighting of the market approach based on comparable public company revenue multiples and the income approach based on the DCF method, as further
discussed under below under “Determination of Estimated Value.”

 Given the absence of a public trading market for the Company’s common
stock, the Board exercised its judgment and considered a number of objective and subjective factors to determine the best estimate of the fair value of the Company’s common stock at each grant date as well as the Valuations, developments in the
Company’s operations, actual operating results and financial performance and capital resources, the conditions in the Company’s industry and the economy and capital markets in general, the stock price performance and volatility of
comparable public companies, the likelihood of achieving a liquidity event for shares of the Company’s common stock underlying these stock options, such as a sale of the Company or an initial public offering, and the lack of liquidity of the
Company’s common stock, among other factors.

 As described in the Registration Statement, in November 2018, the Company effected a one-for-fifteen reverse stock split for its common stock (the “Reverse Stock Split”) as well as the conversion of each share of the Company’s
then-outstanding preferred stock to one share of common stock (the “Conversion”). Except as otherwise indicated herein, all figures presented give effect to the Reverse Stock Split and the Conversion.

After the Reverse Stock Split and the Conversion, commencing in November 2018 and continuing through January 2019, the Company issued and sold shares of its
common stock on an “arms’-length” basis in several tranches at a purchase price per share of $7.18 to multiple investors, several of which were existing investors of the Company (the “Common Stock Financing”).

 Determination of Estimated Value

 The
valuation approaches used by the independent third-party firm includes the following:

 Market Approach: Market Multiple of Revenues

The market approach attempts to value an asset or security by examining observable market values for similar assets or securities. In each Valuation, the
analysis estimated the Company’s total equity valuation based on a multiple of the Company’s trailing 12 months of revenues. The multiplier was determined using enterprise value multiples of revenues for several publicly traded companies
within the Company’s industry.

[*]
 Certain confidential information contained in this letter, marked by brackets, has been omitted and filed
separately with the Commission pursuant to 17 C.F.R. §200.83.

 Cooley LLP 3175 Hanover Street Palo Alto, CA
94304-1130

 t: (650) 843-5000 f: (650) 849-7400 cooley.com

 Page Four

 Income Approach: Discounted Cash Flow

The income approach attempts to value an asset or security based on the expectation of a stream of future benefits, commonly through the DCF method. Under the
DCF method, the Company’s projected after-tax free cash flows were discounted back to present value using a discount rate. The discount rate, known as the weighted average cost of capital, accounts for
the time value of money and the appropriate degree of risk inherent in the Company’s business. In addition to the value of the annual cash flows, a terminal value is projected at the end of the forecast period. Both the terminal value and the
future cash flows are discounted back to the valuation date and summed to determine total equity present value. The DCF method requires significant assumptions, in particular, regarding the Company’s projected cash flows and the discount rate
applicable to the Company’s business.

 Allocation of Estimated Value to Outstanding Securities

Option Pricing Method

 The OPM treats securities,
including debt, common stock and preferred stock, as a series of call options on the enterprise’s value, with exercise prices based on the securities’ respective liquidation preferences and conversion values. Accordingly, the common stock
and preferred stock is considered to be a call option with a claim on the enterprise at an exercise price equal to the remaining value immediately after the liquidation preferences are fulfilled and debt is repaid, and considering the relevant
rights of the preferred stock (e.g., participation) as well as the potential dilution from other outstanding securities such as options and warrants.

Illiquidity and Preference Discount

 In determining the
estimated fair value of the Company’s common stock, the Board also considered that (i) the common stock is not freely tradeable in the public markets and (ii) the holders of the common stock did not have control, economic and other
preference rights enjoyed by the holders of the Company’s outstanding preferred stock. The estimated fair value of the Company’s common stock at the date of each Valuation therefore reflects a discount for lack of marketability
(“DLOM”) partially based on the anticipated likelihood and timing of a future liquidity event as well as lack of preference rights.

Summary of Equity Issuances

 To facilitate the
Staff’s review, the table below contains all grants of options to purchase shares of the Company’s common stock and all other issuances of equity securities of the Company made since April 1, 2018 through the date of this letter. The
share numbers, per share exercise price and fair values are all adjusted for the Reverse Stock Split.

[*]
 Certain confidential information contained in this letter, marked by brackets, has been omitted and filed
separately with the Commission pursuant to 17 C.F.R. §200.83.

 Cooley LLP 3175 Hanover Street Palo Alto, CA
94304-1130

 t: (650) 843-5000 f: (650) 849-7400 cooley.com

 Page Five

 Grant/Issue Date

Number of Shares
Underlying Awards
Granted / Shares
Sold

Exercise Price Per
Share / Price Per
Share

Estimated Fair
Value Per Share on
Date of Grant

Fair Value Per
Share for Financial
Reporting
Purposes

 Options granted in September 2018

458,057

$0.90

$0.90

$0.90

 Common Stock Financing:

November 2018 to January 2019

1,498,533

$7.18

N/A

N/A

 Options and restricted stock units granted in April 2019

800,000

$10.94

$10.94

$10.94

 September 2018 Grants

The Company, with the assistance of a third-party valuation firm, performed a valuation of the Company’s common stock as of August 31, 2018 on a non-controlling, non-marketable basis using a weighting of the market approach based on a market multiple of trailing 12 months of revenues and the income approach
based on the DCF method. The analysis applied a 60% weighting to the market approach equity value and a 40% weighting to the income approach equity value, with a DLOM of 40.1%.

The market approach yielded a total equity value of approximately $[***] million using a multiplier of 1.07. The DCF method yielded a total equity value of
approximately $[***] million. The present value of after-tax free cash flows projected through 2020 was determined to be approximately $[***] million, after applying present value factors of 0.951, 0.779 and
0.577 for the three-month period ended December 31, 2018, fiscal year 2019 and fiscal year 2020, respectively. The terminal present value was determined to be approximately $[***] million, after applying a 0.496 present value factor, based on a
market multiple of projected revenues at the end of the forecast period. The total equity value was determined by taking the sum of the present values of after-tax free cash flows and terminal value. Based on
the above, the analysis resulted in an equity value of approximately $[***] million after weighting the market approach equity value at 60% and the income approach equity value at 40%.

The third-party valuation firm utilized the OPM back-solve approach in t