SecProbe.io

September 24, 2018
Ryan Perfit
Chief Financial Officer
Fluent, Inc.
33 Whitehall Street, 15th Floor
New York, NY 10004
Re:Fluent, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed March 14, 2018
Form 10-Q for the Fiscal Quarter Ended June 30, 2018
Filed August 8, 2018
File No. 001-37893
Dear Mr. Perfit:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2017
Summary of significant accounting policies
(h) Goodwill, page F-14
1.We note goodwill represents a substantial element of your Balance Sheet.  You
disclose that the results of your impairment testing indicated the fair value of your
reporting units exceeded their carrying amount.  We note that your Information Services
reporting unit has historically incurred substantial losses from operations.  Please modify
your disclosure to state, if true, that the results of your impairment testing indicate the fair
values of each reporting unit substantially exceed their carrying values.  Otherwise, please
disclose (either here or within Critical Accounting Policies in MD&A) the amount or

 FirstName LastNameRyan Perfit
 Comapany NameFluent, Inc.
 September 24, 2018 Page 2
 FirstName LastName
Ryan Perfit
Fluent, Inc.
September 24, 2018
Page 2
percentage by which each reporting unit's fair value exceeds its carrying value.
Form 10-Q for the Fiscal Quarter Ended June 30, 2018
Summary of significant accounting policies
(c) Revenue recognition, page 7
2.You disclose on page 8 that you have a right to payment from customers in an amount that
corresponds directly with the value of the performance completed to date.  We note that a
significant portion of your accounts receivable as of June 30, 2018 and December 31,
2017 consists of unbilled revenue.  Please expand your revenue policy to describe the
circumstances that result in delays between revenue recognition and the issuance of
customer invoices.  Please tell us the extent to which your unbilled revenue balances as of
June 30, 2018 have been subsequently invoiced and how long it took to issue those
invoices.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Joseph Cascarano, Staff Accountant, at (202) 551-337or Lisa Haynes
Etheredge, Staff Accountant, at (202) 551-3424 with any questions.
Sincerely,
Division of Corporation Finance
Office of Telecommunications