SecProbe.io

September 28, 2018
Richard Mills
Chief Executive Officer
Creative Realities, Inc.
13100 Magisterial Drive, Suite 100
Louisville, KY 40223
Re:Creative Realities, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed September 21, 2018
File No. 333-225876
Dear Mr. Mills:
            We have reviewed your amended registration statement 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 by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 2 to Form S-1
Prospectus Summary, page 1
1.Please clarify whether the closing of this offering is a condition to the acquisition of
Allure Global Solutions, Inc.  If so, include disclosure that the acquisition may not occur
if you are not approved for listing on The NASDAQ Capital Market, which is a condition
of this offering.
Signatures, page II-7
2.Instruction 1 to Signatures of Form S-1 requires signatures of your principal executive
officer or officers, your principal financial officer, your controller or principal accounting

 FirstName LastNameRichard Mills
 Comapany NameCreative Realities, Inc.
 September 28, 2018 Page 2
 FirstName LastName
Richard Mills
Creative Realities, Inc.
September 28, 2018
Page 2
officer and at least a majority of the board of directors or persons performing similar
functions.  To the extent that you are signing in more than one capacity, indicate each
capacity in which you are signing.  Please revise.
            You may contact Michael Foland, Attorney-Advisor, at (202) 551-6711 or Jan Woo,
Legal Branch Chief, (202) 551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services
cc:       Paul Chestovich