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CORRESP
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filename1.htm

Blink
Charging Co.

3284
N 29th Court

Hollywood,
FL 33020-1320

January
25, 2018

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:
    Blink
    Charging Co.

    Amendment
    No. 5 to Registration Statement on Form S-1

    Filed
    January 11, 2018

    File
    No. 333-214461

Dear
Mr. Mancuso:

This
letter provides the response of Blink Charging Co. (the “Company”) to the oral comment provided by a member of the
Staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange to our securities counsel
on January 23, 2018. For your convenience, the matters are listed below, followed by the Company’s responses:

Email
to Blink Network

    1.
    We
    note that the Company’s CEO has sent an email to members of the Blink Network. Please clarify whether the Company is
    engaging in a Directed Share Program with regard to members of the Blink Network and, if so, please disclose the Directed
    Share Program in your registration statement. In addition, please file this email as a Free Writing Prospectus or please explain
    why you believe this is not a Free Writing Prospectus.

    RESPONSE:
    In
                                         response to the Staff’s comment regarding a Directed Share Program, we note that
                                         the email states that “the underwriters of that offering have agreed to consider
                                         reserving a number of the shares of common stock being offered for our Blink members.”
                                         The underwriters have not agreed to reserve a certain number of shares and are under
                                         no obligation to do so. There are no plans for a Directed Share Program at this time.

        In
        response to the Staff’s comment regarding whether the email is a Free Writing Prospectus, it is our view that it
        is a communication that should not be deemed (i) an “offer” or “solicitation” under the Securities
        Act, or (ii) a prospectus because the email falls under the safe harbor provided under Securities Act Rule 134.

        (i)The
        email was not an “offer” or “solicitation” because it clearly states that “This communication
        shall not constitute an offer to sell or the solicitation of an offer to buy” and “nor shall there
        be any sale of the referenced securities in any state or jurisdiction in which such offer, solicitation, or sale would
        be unlawful prior to registration or qualification under the securities laws of any such state or jurisdiction.”
        An investor could not at the time of receipt of the email, nor currently, purchase any security offered in the current
        offering.

        (ii)
        There was no information regarding the offering in the email (including items allowed by Rule 134(a) such as title of
        security, price, intended use of proceeds, or schedule for the offering), there was a legend in the communication that
        stated, among other items, that “the offering will be made by means of a prospectus only . . . Before you invest,
        you should read the prospectus included in the registration statement for more complete information about the Company
        and this offering . . . This communication shall not constitute an offer to sell or the solicitation of an offer to buy”
        and the email is an electronic communication that provides an active hyperlink to an active hyperlink to a prospectus
        that meets the requirements of section 10 of the Securities Act. This hyperlink takes to you to a preliminary prospectus
        that clearly states that “we may not sell these securities until the registration statement filed with the Securities
        and Exchange Commission is effective. This prospectus is not an offer to sell these securities and is not soliciting an
        offer to buy these securities in any jurisdiction where the offer or sale is not permitted.”

    Sincerely,

    Blink
    Charging Co.

    By:
    /s/
    Michael Calise

    Name:
    Michael
    Calise

    Title:

    Chief
    Executive Officer