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 April 20, 2026

Ravi Jani
Chief Financial Officer
Real Brokerage Inc
701 Brickell Avenue, 17th Floor
Miami, FL, 33131

 Re: Real Brokerage Inc
 Annual Report on Form 40-F
 Filed March 04, 2026
 File No. 001-40442
Dear Ravi Jani:

 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.

Annual Report on Form 40-F
Note 2. Summary of Significant Accounting Policies
Y. Revenue Share, page 15

1. We note the Company has a revenue sharing plan where its agents can
receive additional
 income from real estate transactions consummated by agents they have
attracted to the
 Company and that the amounts paid to agents are included as part of
marketing expenses.
 Please tell us how you determined these amounts are not considered a
cost of sales citing
 all relevant accounting literature within your response. Include within
your response if
 such additional income reduces the commissions paid to the recruited
agents or if the
 recruited agents still receive their full commission.
Financial Statements
Note 7. Stock-Based Payment Arrangements
D. Restricted Share Units
Production and Service-Based RSUs, page 24

2. Related to our comment on Revenue Share, please tell us if Production
and Service-
 Based RSUs result in decreased commissions to any of your agents.
 April 20, 2026
Page 2

 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 William Demarest at 202-551-3432 or Shannon Menjivar at
202-551-3856
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Real Estate
& Construction
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