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        ATTORNEYS AT LAW

        777 East Wisconsin Avenue

        Milwaukee, WI 53202-5306

        414.271.2400 TEL

        414.297.4900 FAX

        www.foley.com

        WRITER’S DIRECT LINE

414.297.5642

        EMAIL: jkwilson@foley.com

February 5, 2018

        Division of Corporation Finance

        Office of Telecommunications

        Securities and Exchange Commission

        100 F Street, N.E.

        Washington, D.C. 20549-3561

        Attn:      Joshua Shainess

        Celeste M. Murphy

 RE: Hudson Global, Inc.

    Preliminary Proxy Statement on Schedule 14A

    Filed January 25, 2018 File
No. 000-50129

Ladies and Gentlemen:

On behalf of Hudson
Global, Inc. (the “Company”), I am responding to the comment contained in the comment letter of the Staff of the Division
of Corporation Finance (the “Staff”), of the U.S. Securities and Exchange Commission (the “Commission”),
dated February 2, 2018 with respect to the above-referenced Preliminary Proxy Statement on Schedule 14A filed by the Company.

For the convenience
of the Staff, the comment contained in the Staff’s comment letter is set forth below and indicated in bold and italics, followed
by the Company’s response immediately after the comment.

Preliminary Proxy Statement on Schedule 14A

General

 1. Please tell us why the Sale Resolution proposal is not unbundled into three separate proposals. Provide your analysis
under Rule 14a-4(a)(3) and (b)(1). Refer to our Compliance and Disclosure Interpretations 101.01 and 101.02 dated January 24, 2014
(regarding unbundling under Rule 14a-4(a)(3) generally).

The Company has considered
Rule 14a-4(a)(3) and (b)(1) under the Securities Exchange Act of 1934, as amended, and the Staff’s Compliance and Disclosure
Interpretations (“CD&I”) 101.01 and 101.02 dated January 24, 2014 and respectfully submits that the Sale Resolution
proposal does not contain “separate matters” required to be presented in separate proposals.

Rule 14a-4(a)(3) requires
that the form of proxy “[s]hall identify clearly and impartially each separate matter intended to be acted upon, whether
or not related to or conditioned on the approval of other matters, and whether proposed by the registrant or by security holders.”
The purpose of Rule 14a-4(a)(3), as expressed in Exchange Act Release No. 31326 (October 16, 1992), is to permit stockholders to
communicate their views on each of the matters put to a vote, and to not be compelled to approve parts of packaged matters they
might not approve if they could be presented independently.

CD&I 101.01 addresses
the situation where stockholder approval is sought for a charter amendment to modify multiple terms of outstanding preferred stock
in connection with granting concessions to the preferred stockholders. The Staff concluded that the multiple modifications could
be bundled because they were so “inextricably intertwined” as to effectively constitute a single matter. Also CD&I
101.02 addresses the situation where multiple immaterial charter amendments are bundled with a material amendment as part of a
single proposal to amend and restate the charter. The Staff concluded that the proposals could be bundled because the immaterial
amendments did not substantively affect stockholder rights, but also noted that the analysis of whether matters need to be unbundled
under Rule 14a-4(a)(3) is not governed by the fact that, for state law purposes, these amendments could be presented to stockholders
as a single restatement proposal.

        Boston

        Brussels

        CHICAGO

        Detroit

        JACKSONVILLE

        LOS ANGELES

        MADISON

        MIAMI

        MILWAUKEE

        NEW YORK

        ORLANDO

        SACRAMENTO

        SAN DIEGO

        SAN FRANCISCO

        SILICON VALLEY

        TALLAHASSEE

        TAMPA

        TOKYO

        WASHINGTON, D.C.

February 5, 2018

Page 2

The Company believes
that CD&I 101.01 or 101.02 are not applicable because, unlike the examples provided where stockholder approval would be required
for each separate item regardless if they were bundled, no stockholder vote would be required or sought if the transactions that
are the subject of the Sale Resolution proposal were separately pursued. Under Section 271(a) of the Delaware General Corporation
Law, only one vote of the stockholders is contemplated and required to sell substantially all of a corporation’s assets regardless
of how many transactions are involved. None of the three transactions by themselves would constitute a sale of substantially all
of the Company’s assets and if each sale were completed on a stand-alone basis, no stockholder vote would be required or
sought by the Company.

Furthermore, the Company
believes that the unbundling requirements of Rule 14a-4(a)(3) are inapplicable to the Company because the closing of each sale
transaction is contingent on the closing of each other sale transaction. Consequently, each of the sale transactions are inextricably
linked components of one unitary matter: the adoption of a resolution to sell substantially all of the Company’s assets.

Finally, the Company
believes that unbundling the Sale Resolution proposal and presenting each sale transaction as separate proposals would potentially
confuse stockholders by suggesting that it is possible for one or two of the sale transactions to proceed without all three proceeding
as the closing of each sale transaction is contingent on the closing of each other sale transaction.

*        *
       *

Should you have any
questions relating to the foregoing matters or wish to discuss further any of the responses above, please direct any communications
to the undersigned at (414) 297-5642 or jkwilson@foley.com.

    Very truly yours,

    /s/ John K. Wilson

    John K. Wilson

    CC:
    Stephen A. Nolan

    Patrick Lyons

    Philip A. Skalski

    Hudson Global, Inc.

    Benjamin F. Garmer

    Foley & Lardner LLP