SecProbe.io

CORRESP
 1
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 CISO
GLOBAL, INC.
 6900 E. Camelback Road, Suite 900

 Scottsdale,
Arizona 85251

 July
1, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Trade & Services

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:
Eddie Kim

 Re: CISO
 Global, Inc.
 Registration
 Statement on Form S-3

 Filed
 June 26, 2025

 File
 No. 333-288353

 Dear
Mr. Kim:

 In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, CISO Global, Inc. (the "Company")
hereby requests that the effective date of the above-captioned Registration Statement be accelerated to 5:00 p.m., Eastern time, on Monday,
July 7, 2025, or as soon as practicable thereafter.

 The
Company acknowledges that (1) should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement
effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; (2) the action of
the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and (3) the Company
may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

 Very
truly yours,

 CISO
 GLOBAL, INC.

 By:
 /s/
 Debra L. Smith

 Debra
 L. Smith

 Chief
 Financial Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 2, 2025

David Jemmett
Chief Executive Officer
CISO Global, Inc.
6900 E. Camelback Road, Suite 900
Scottsdale, Arizona 85251

 Re: CISO Global, Inc.
 Registration Statement on Form S-3
 Filed June 26, 2025
 File No. 333-288353
Dear David Jemmett:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Eddie Kim at 202-551-8713 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Katherine A. Beck
</TEXT>
</DOCUMENT>

CORRESP
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CISO
GLOBAL, INC.

6900
E. Camelback Road, Suite 900

Scottsdale,
AZ 85251

January
3, 2025

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
DC 20549

    Re:
    CISO
    Global, Inc.

    Registration
    Statement on Form S-3, File No. 333-284002

REQUEST
FOR ACCELERATION OF EFFECTIVENESS

Requested
Date: Monday January 6, 2025

Requested
Time: 4:30 pm, Eastern Time

Ladies
and Gentlemen:

CISO
Global, Inc. (the “Company”) hereby requests that the effective date of the Company’s Registration Statement on Form
S-3 (File No. 333-284002), be accelerated pursuant to Rule 461 under the Securities Act of 1933, as amended, so that it is declared and
becomes effective at 4:30 pm Eastern Time on Monday, January 6, 2025, or as soon thereafter as possible.

Please
contact our counsel, Steven Lipstein of Lucosky Brookman LLP, at (732) 395-4416, with any questions you may have regarding this request.
In addition, the Company requests that you kindly notify Mr. Lipstein by telephone when this request for acceleration has been granted.

    Sincerely
    yours,

    CISO
    GLOBAL, INC.

    /s/
    Debra L. Smith

    Debra
    L. Smith

    Chief
    Financial Officer

January 2, 2025
Debra L. Smith
Chief Financial Officer
CISO Global, Inc.
6900 E. Camelback Road, Suite 900
Scottsdale, AZ 85251
Re:CISO Global, Inc.
Registration Statement on Form S-3
Filed December 23, 2024
File No. 333-284002
Dear Debra L. Smith:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Kate Beukenkamp at 202-551-3861 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Steven Lipstein

CORRESP
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CERBERUS
CYBER SENTINEL CORPORATION

6900
E. Camelback Road, Suite 240

Scottsdale,
Arizona 85251

June
24, 2022

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Nicholas Nalbantian

    Re:
    Cerberus
    Cyber Sentinel Corporation

    Registration
    Statement on Form S-3 (File No. 333-265574)

    Request
    for Acceleration

Dear
Mr. Nalbantian:

In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Cerberus Cyber Sentinel Corporation
(the “Company”) hereby requests that the effective date of the above-captioned Registration Statement be accelerated to 10:00
a.m., Eastern time, on Monday, June 27, 2022, or as soon as practicable thereafter.

The
Company acknowledges that (1) should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement
effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; (2) the action of
the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and (3) the Company
may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

    Very
    truly yours,

    CERBERUS
    CYBER SENTINEL CORPORATION

    By:
    /s/
    David G. Jemmett

    David
    G. Jemmett

    Chief
    Executive Officer

United States securities and exchange commission logo
June 22, 2022
David Jemmett
Chief Executive Officer
Cerberus Cyber Sentinel Corp
6900 E. Camelback Road, Suite 240
Scottsdale, AZ 85251
Re:Cerberus Cyber Sentinel Corp
Registration Statement on Form S-3
Filed June 14, 2022
File No. 333-265574
Dear Mr. Jemmett:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Nicholas Nalbantian at 202-551-7470 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Katherine A. Beck

CORRESP
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January 13, 2022

Via
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549-3720

Attention:             Cara Wirth

    Re:
    Cerberus
    Cyber Sentinel Corporation

    Registration
    Statement on Form S-1/A

    Filed
    January 13, 2022

Acceleration
Request

    Requested
    Date:
    January
    13, 2022

    Requested
    Time:
    4:00
    PM Eastern Time

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Cerberus Cyber Sentinel Corporation (the “Company”) hereby
requests that the above-referenced Registration Statement on Form S-1 (the “Registration Statement”) be declared effective
at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable, or at such
later time as the Company may request by telephone to the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”). The Company hereby authorizes David R. Earhart of Gray Reed & McGraw LLP, counsel for the
Company, to make such request on the Company’s behalf.

The
Company requests that it be notified of the effectiveness of the Registration Statement by telephone to David R. Earhart of Gray Reed
& McGraw LLP, at (469) 320-6041. Please direct any questions or comments regarding this acceleration request to David R. Earhart.

    Sincerely,

    Cerberus
    Cyber Sentinel Corporation

    By:

    /s/
    David G. Jemmett

    David
G. Jemmett

    Chief
Executive Officer

    cc:
    David
    R. Earhart

    Gray
Reed & McGraw LLP

CORRESP
1
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Boustead
Securities LLC

6
Venture #395

Irvine,
CA 92618

January
13, 2022

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549-3720

Attention:
Cara Wirth

    Re:
    Cerberus
    Cyber Sentinel Corporation

    Registration
    Statement on Form S-1/A

    Filed
    January 13, 2022

Acceleration
Request

    Requested
    Date: January 13, 2022

    Requested
    Time: 4:00 PM Eastern Time

Ladies
and Gentlemen:

In
connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the
“Act”), we, as the underwriters, hereby join in the request of Cerberus Cyber Sentinel Corporation (the “Company”)
that the effective date of the Registration Statement on Form S-1/A, filed with the Securities and Exchange Commission on January
13, 2022, be accelerated so that it will be declared effective at 4:00 p.m., Eastern Time (US), on Thursday, January 13,
2022, or at such time as the Company or its outside counsel, Gray Reed & McGraw LLP, may request via a telephone call to the
staff of the Division of Corporation Finance of the Securities and Exchange Commission.

Pursuant
to Rule 460 under the Act, we wish to advise you that, as underwriters in the above offering, we will distribute as many copies of the
preliminary prospectus to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution
of the preliminary prospectus.

The
undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating
underwriters that they have complied and will comply, with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very
    truly yours,

    BOUSTEAD
    SECURITIES, LLC

    By:
    /s/
    Keith Moore

    Name:
    Keith
    Moore

    Title:
    Chief
    Executive Officer

CORRESP
1
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December
14, 2021

Via
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549-3720

Attention:
Cara Wirth

    Re:
    Cerberus Cyber Sentinel Corporation

    Registration Statement on Form S-1

    Filed December 14, 2021

Acceleration
Request

    Requested Date: December 16, 2021

    Requested
    Time: 5:25 PM Eastern Time

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Cerberus Cyber Sentinel Corporation (the “Company”) hereby
requests that the above-referenced Registration Statement on Form S-1 (the “Registration Statement”) be declared effective
at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable, or at such
later time as the Company may request by telephone to the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”). The Company hereby authorizes David R. Earhart of Gray Reed & McGraw LLP, counsel for the
Company, to make such request on the Company’s behalf.

The
Company requests that it be notified of the effectiveness of the Registration Statement by telephone to David R. Earhart of Gray Reed
& McGraw LLP, at (469) 320-6041. Please direct any questions or comments regarding this acceleration request to David R. Earhart.

    Sincerely,

    Cerberus
    Cyber Sentinel Corporation

    By:
    /s/
    David G. Jemmett

    David
    G. Jemmett

    Chief
    Executive Officer

    cc:
    David
    R. Earhart

    Gray
    Reed & McGraw LLP

CORRESP
1
filename1.htm

Boustead
Securities LLC

6
Venture #395

Irvine,
CA 92618

December
14, 2021

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549-3720

Attention:
Cara Wirth

    Re:
    Cerberus
    Cyber Sentinel Corporation

    Registration
    Statement on Form S-1

    Filed
    December 14, 2021

Acceleration
Request

    Requested
    Date: December 16, 2021

    Requested
    Time: 5:25 PM Eastern Time

Ladies
and Gentlemen:

In
connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the
“Act”), we, as the underwriters, hereby join in the request of Cerberus Cyber Sentinel Corporation that the effective date
of the Registration Statement be accelerated so that it will be declared effective at 5:25 p.m., Eastern Time (US), on Thursday,
December 16, 2021, or at such time as the Company or its outside counsel, Gray Reed & McGraw LLP, may request via a telephone call
to the staff of the Division of Corporation Finance of the Securities and Exchange Commission.

Pursuant
to Rule 460 under the Act, we wish to advise you that, as underwriters in the above offering, we will distribute as many copies of the
preliminary prospectus to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution
of the preliminary prospectus.

The
undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating
underwriters that they have complied and will comply, with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very
    truly yours,

    BOUSTEAD
    SECURITIES, LLC

    By:
    /s/
    Keith Moore

    Name:
    Keith
    Moore

    Title:
    Chief
    Executive Officer

United States securities and exchange commission logo
November 3, 2021
David G. Jemmett
Chief Executive Officer
Cerberus Cyber Sentinel Corporation
6900 E Camelback Road, Suite 240
Scottsdale, AZ 85251
Re:Cerberus Cyber Sentinel Corporation
Draft Registration Statement on Form S-1
Submitted October 28, 2021
CIK No. 0001777319
Dear Mr. Jemmett:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours prior
to the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for
acceleration. 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 Cara Wirth at (202) 551-7127 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       David R. Earhart

November 26, 2019
David G. Jemmett
Chief Executive Officer
Cerberus Cyber Sentinel Corp.
7333 E. Doubletree
Suite D270
Scottsdale, Arizona 85258
Re:Cerberus Cyber Sentinel Corp.
Registration Statement on Form 10-12G
Filed October 2, 2019
File No. 000-56059
Dear Mr. Jemmett:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

October 29, 2019
David G. Jemmett
Chief Executive Officer
Cerberus Cyber Sentinel Corp.
7333 E. Doubletree
Suite D270
Scottsdale, Arizona 85258
Re:Cerberus Cyber Sentinel Corp.
Registration Statement on Form 10-12G
Filed October 2, 2019
File No. 000-56059
Dear Mr. Jemmett:
            We have reviewed your filing 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 and any amendment you may file in response to these
comments, we may have additional comments.
Registration Statement on Form 10-12G
Item 6. Executive Compensation
Material Terms of Employment, page 30
1.Please discuss the "additional compensation," other than base salary, that you may provide
to your executive officers. In this regard, we note that the Employment Agreements filed
as Exhibits 10.2 and 10.3 include provisions for the payment of discretionary bonuses
based on performance and company objectives that may be issued to your executive
officers.
Exclusive Forum , page 33
2.We note your revised disclosure in response to comment 9 and we reissue the comment
in-part.  In this regard, it appears that your Bylaws do not include an exclusive forum

 FirstName LastNameDavid G.  Jemmett
 Comapany NameCerberus Cyber Sentinel Corp.
 October 29, 2019 Page 2
 FirstName LastName
David G.  Jemmett
Cerberus Cyber Sentinel Corp.
October 29, 2019
Page 2
provision. Please revise your registration statement to ensure consistency, as your
disclosure in this section currently references your Bylaws.  In addition, with respect to
the exclusive forum provision contained in your charter, please disclose whether the
provision applies to actions arising under the Securities Act or Exchange Act.  If so,
please also state that there is uncertainty as to whether a court would enforce such
provision; in this regard, we note that section 22 of the Securities Act creates concurrent
jurisdiction for federal and state courts over all suits brought to enforce any duty or
liability created by the Securities Act or the rules and regulations thereunder.  If this
provision does not apply to actions arising under the Securities Act or Exchange Act,
please also ensure that the exclusive forum provision in the governing document states
this clearly, or tell us how you will inform investors in future filings that the provision
does not apply to any actions arising under the Securities Act or Exchange Act.
Financial Statements and Exhibits, page F-1
3.We note your disclosure on page F-42 that the "Company had recorded an advance to the
majority stockholder of the Company." Given that your majority stockholder is your Chief
Executive Officer, please tell us, and to the extent necessary disclose the actions that will
be taken to ensure that this arrangement will be extinguished prior the completion of the
initial public offering, or tell us why Section 402(a)(k)(1) of Sarbanes-Oxley Act of 2002
does not apply to this advance. In this regard, Section 402 (a)(k)(1) prohibits public
companies from extending or maintaining credit in the form of a personal loan to or for
any director or executive officer.
            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 Jennifer López at (202) 551-3792 or Lilyanna Peyser at (202) 551-
3222 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

June 24, 2019
David Jemmett
Chief Executive Officer
CERBERUS CYBER SENTINEL CORP
7333 E. Doubletree
Suite D270
Scottsdale, AZ 85258
Re:CERBERUS CYBER SENTINEL CORP
Form 10-12G
Filed May 28, 2019
File No. 000-56059
Dear Mr. Jemmett:
            We have reviewed your filing 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 and any amendment you may file in response to these
comments, we may have additional comments.
Form 10-12G
General
1.Please note that the Form 10 goes effective by lapse of time 60 days after the date filed
pursuant to Section 12(g)(1) of the Securities Exchange Act of 1934, which is July 27,
2019.  At that time, you will be subject to the reporting requirements under Section 13(a)
of the Securities Exchange Act of 1934.  In addition, we will continue to review your
filing until all of our comments have been addressed.  If the review process has not been
completed before that date you should consider withdrawing the registration statement to
prevent it from becoming effective and refiling it at such time as you are able to respond
to any remaining issues or comments.

 FirstName LastNameDavid Jemmett
 Comapany NameCERBERUS CYBER SENTINEL CORP
 June 24, 2019 Page 2
 FirstName LastNameDavid Jemmett
CERBERUS CYBER SENTINEL CORP
June 24, 2019
Page 2
Forward Looking Statements, page 1
2.Please revise the last sentence of this paragraph to clarify that your disclosure will be
updated to the extent required by law.
Cybersecurity Consulting, page 2
3.We note your disclosure in the second sentence of the first paragraph regarding incentives
to sell security products. Please explain what you mean by this statement and describe any
incentives you may offer that are material to your business plan
Item 1. Business, page 2
4.We note your disclosure that you intend to acquire other businesses in order to provide
your intended services. Please clarify if you are currently able to provide all of the
services discussed in this section. If not, please clarify the services that you are currently
providing and are able to provide and the services that you hope to be able to provide in
the future.
5.Throughout your document you utilize industry jargon. For example only, please provide
a better explanation for "CISO as a service." If you must include technical terms in the
body of your prospectus that are understood only by industry experts, you must make
every effort to concisely explain these terms where you first use them. In addition, please
do not use technical terms or industry jargon in your explanations. Further, we note your
use of acronyms through your document. Please ensure that you define acronyms where
you first use them. For example only, please define "SOC2, PCI DSS, HIPPA, HITRUST,
and NIST."
Employees, page 7
6.We note your disclosure that most of your employees are independent contractors. Please
explain your arrangements with these individuals and add risk factor disclosure, as
appropriate, regarding the risks of relying upon independent contractors to perform
services for your clients.
Item 5. Directors and Executive Officers, page 26
7.Please provide all of the disclosure required by Item 401 of Regulation S-K. For example,
please disclose each of the entities Mr. Jemmet has been associated with in at least the
past five years, his position at the entity and disclose when he began working at each
entity and when he ceased working at each entity.  Further, for each of your directors,
please discuss the specific experience, qualifications, attributes or skills that led to the
conclusion that the individual should serve as your director in light of your business and
structure. Please refer to Item 401(e) of Regulation S-K.

 FirstName LastNameDavid Jemmett
 Comapany NameCERBERUS CYBER SENTINEL CORP
 June 24, 2019 Page 3
 FirstName LastName
David Jemmett
CERBERUS CYBER SENTINEL CORP
June 24, 2019
Page 3
Item 6. Executive Compensation, page 28
8.We note your disclosure that you and your subsidiary did not pay any compensation in
2018 or other prior periods. Please clarify whether, at this point, you intend to pay
compensation in 2019, and, if so, any known terms related to such compensation
arrangements.
Exclusive Forum, page 33
9.We note your disclosure on page 33 that the United States District Court for the District of
Arizona sitting in Phoenix, Arizona shall be the sole and exclusive forum for certain
actions, claims and proceedings.  However, your Bylaws included as an exhibit to the
Form 10 do not refer to the same, and your Certificate of Incorporation contains an
exclusive forum provision for the Court of Chancery of the State of Delaware that is
different from the provision disclosed on page 33.  Please revise your exhibits and Form
10 to be consistent.  We may have further comments.
            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 William Demarest at 202-551-3432 or Daniel Gordon, Senior Assistant
Chief Accountant, at 202-551-3486 if you have questions regarding comments on the financial
statements and related matters.  Please contact Stacie Gorman at 202-551-3585 or Sonia Barros,
Assistant Director, at 202-551-3655 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate and
Commodities
cc:       David R. Earhart, Esq.