SecProbe.io

CORRESP
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filename1.htm

Blink
Charging Co.

3284
N 29th Court

Hollywood,
FL 33020-1320

December
7, 2017

VIA
EDGAR

Russell
Mancuso, Branch Chief

Office
of Electronics and Machinery

Mail
Stop 3030

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street N.E.

Washington,
D.C. 20549

    Re:
    Car
    Charging Group, Inc. (now Blink Charging Co.)

    Amendment
    No. 2 to Registration Statement on Form S-1

    Filed
    July 6, 2017

    File
    No. 333-214461

Dear
Mr. Mancuso:

Blink
Charging Co. (formerly known as Car Charging Group, Inc.) (the “Company”) is in receipt of your comment letter dated
July 24, 2017 regarding the above referenced filing. As requested in your letter, we have provided responses to the questions
raised by the staff. For your convenience, the matters are listed below, followed by the Company’s responses:

Prospectus
Cover Page

    1.
    Clarify
    whether investors have a choice of purchasing a warrant or a share of common stock. If you are offering a unit, please revise
    throughout your registration statement to clarify, and revise your fee table as appropriate.

    RESPONSE:
    In
    response to the staff’s comment, we have revised our registration statement to clarify that we are offering units. These
    units will not be issued or certificated. In response to the staff’s comment, we have revised our fee table.

    2.
    Tell
    us when you intend to complete the blanks that you currently have included regarding the offering price range. Also tell us
    when information based on that range will be reflected in the related information throughout your registration statement.

    RESPONSE:
    On
    August 28, 2017, our securities counsel and Tim Buchmiller of the Securities and Exchange Commission had a telephone conversation
    regarding this comment. Our securities counsel clarified that the offering price will be based on the market price at the
    time of the pricing of the offering and that, as a result, we are deleting the reference to an offering price range.

    3.
    You
    indicate that the number of shares and warrants are based on an assumed public offering price of $9.25 per share. Revise to
    disclose a fixed volume of securities that you are offering.

    RESPONSE:
    In
    response to the staff’s comment, we have revised to disclose a fixed volume of securities that we are offering.

Russell
Mancuso, Branch Chief

Securities and Exchange Commission

December 7, 2017

Use
of Proceeds, page 29

    4.
    Disclose
    in this section all obligations to be paid with proceeds of this offering. We note for example the tax obligations mentioned
    on page 12 and payments to Mr. Farkas mentioned on page 78.

    RESPONSE:
    In
    response to the staff’s comment, we have revised to disclose in the Use of Proceeds section on page 29 all obligations
    to be paid with the proceeds of this offering including tax obligations and payments to Mr. Farkas.

    5.
    Please
    clarify whether your reference on pages 62, 78 and 79 to securities “sold in in this offering” means that you
    are intending the securities registered for sale by this registration statement to be issued to officers.

    RESPONSE:
    In
    response to the staff’s comment, we have clarified that the Company will not be selling or issuing units registered
    in the registration statement to officers.

Exhibits

6.

    Please
    tell us which exhibit represents the warrants to be sold in this offering.

    RESPONSE:
    We
    will be filing the warrants to be sold in this offering as an exhibit (currently scheduled to be Exhibit 3.14) to a future
    pre-effective amendment to the registration statement.

    Sincerely,

    Blink
    Charing Co.

    By:
    /s/
    Michael Calise

    Name:
    Michael
    Calise

    Title:

    Chief
    Executive Officer