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June 13, 2024
Gust Kepler
President and Chief Executive Officer
Blackboxstocks Inc.
5430 LBJ Freeway, Suite 1485
Dallas, Texas 75240
Re:Blackboxstocks Inc.
Form 10-K for the fiscal year ended December 31, 2023
File No. 001-41051
Dear Gust Kepler:
            We have reviewed your filing and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Balance Sheets, page F-2
1.We note that you include right of use lease assets within the subtotal of property and
equipment. Explain why the presentation of right of use assets together with owned assets
is appropriate considering they are subject to different risks. Refer to ASC 842-30-50-13.
Notes to Financial Statements, page F-6
2.We note your disclosure elsewhere that you “maintain a growing base of members that
spans over 40 countries.” Please revise to disclose geographic information pursuant to
ASC 280-10-50-41.
Note 2. Summary of Significant Accounting Policies, page F-8
3.Please tell us why 2,400,000 Series B Convertible Preferred Shares are included as
potential additional dilutive securities outstanding at December 31, 2023 considering your
disclosure elsewhere that the Series B Stock was forfeited and cancelled by Evtec Group
as of the date of the Forfeiture Agreement of November 28, 2023.

 FirstName LastNameGust Kepler
 Comapany NameBlackboxstocks Inc.
 June 13, 2024 Page 2
 FirstName LastName
Gust Kepler
Blackboxstocks Inc.
June 13, 2024
Page 2
Controls and Procedures
Evaluation of Disclosure Controls and Procedures, page 31
4.Please revise to disclose the conclusion of your principal executive officer and principal
financial officer as to the effectiveness of disclosure controls and procedures based upon
the full definition contained in Rules 13a-15(e) and 15d-15(e) of the Securities Exchange
Act of 1934. In this regard, your disclosure states that your disclosure controls and
procedures were effective to provide reasonable assurance that information required to be
disclosed in the Company’s periodic filings under the Exchange Act is accumulated and
communicated to your management to allow timely decisions regarding required
disclosure. Tell us and revise to disclose whether your assessment also included whether
your controls and other procedures were designed to ensure that information required to
be disclosed in your reports is recorded, processed, summarized and reported timely. Also
revise your evaluation of disclosure controls and procedures in the Form 10-Q for the
quarterly period ended March 31, 2024, accordingly.
Management's Annual Report on Internal Control Over Financial Reporting, page 32
5.Please also identify the version of the COSO Framework (i.e., the 2013 framework) you
used in your evaluation of the Company's internal control over financial reporting. Refer
to Item 308(a)(2) of Regulation S-K.
            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.
            Please contact Melissa Walsh at 202-551-3224 or Stephen Krikorian at 202-551-3488 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Jeffrey McPhaul