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                                                           April 25, 2019

Leandro Iglesias
Chief Executive Officer
iQSTEL Inc.
300 Aragon Avenue, Suite 375
Coral Gables, FL 33134

       Re: iQSTEL Inc.
           Offering Statement on Form 1-A/A
           Filed on April 15, 2019
           File no. 024-10950

Dear Mr. Iglesias:

      We have reviewed your amended offering statement 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 this letter by amending your offering statement and
providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your offering statement and the
information you
provide in response to these comments, we may have additional comments.

Amended Form 1-A Filed on April 15, 2019

Management's Discussion and Analysis
Liquidity and Capital Resources, page 6

1.    Disclose the total amount of your debt.
Use of Proceeds, page 20

2.    We note your inclusion of the website for SwissLink Carrier AG. Revise
your disclosure
      to clarify whether you are incorporating the contents of the website into
the offering
      statement.
3.    Disclose the material terms of your purchase agreement for SwissLink
Carrier AG.
 Leandro Iglesias
iQSTEL Inc.
April 25, 2019
Page 2
Financial Statements, page F-1

4.       We note it is your intent to acquire the capital stock of SwissLink
Carrier AG. Please
         refer to 8-04 of Regulation S-X and provide audited financial
statements of SwissLink
         Carrier AG, if required. Please also refer to 8-05 of Regulation S-X
and provide pro
         forma financial information to give effect to the acquisition, if
required. If you believe
         that it is not necessary for you to provide this information, please
explain to us why in
         sufficient detail. We refer you to the disclosure requirements of Form
1-A, Part
         F/S(b)(7)(iii).
5.       We note under Use of Proceeds you have signed a Letter of Intent to
acquire the capital
         stock of a Mid-West based Telecom company. Please refer to 8-04 of
Regulation S-X
         and provide audited financial statements of this to be acquired
business, if required.
         Please also refer to 8-05 of Regulation S-X and provide pro forma
financial information to
         give effect to this business combination, if required. If you believe
this information is not
         required, please explain to us why in sufficient detail. We refer you
to the disclosure
         requirements of Form 1-A, Part F/S(b)(7)(iii).
Exhibits

6.       File the purchase agreement for SwissLink Carrier AG as an exhibit.
7.       Refer to Sections 2.03 and 2.06 of the subscription agreement. Remove
the requirement
         that subscribers represent that they have "read" or "understood" the
offering circular and
         any part thereof. Also remove the last sentence in Section 2.06, as
investors are entitled to
         rely on information you have provided, including disclosure in your
offering statement
         regarding the company's business or prospects and its financial
condition.
8.     We note that you have included an indemnification clause in Section 3.10
of the
       subscription agreement, which requires an investor to indemnify, defend
and hold
       harmless the company and various representatives and management. Please
revise your
FirstName LastNameLeandro Iglesias indemnification provision in more detail and
explain how
       offering circular to highlight the
Comapany NameiQSTEL Inc.For example, clarify under what circumstances and for
what
       it applies to investors.
April 25, 2019 an investor should expect to indemnify the company and its
representatives.
       amount Page 2
FirstName LastName
 Leandro Iglesias
FirstName LastNameLeandro Iglesias
iQSTEL Inc.
Comapany NameiQSTEL Inc.
April 25, 2019
Page 25,
April 3 2019 Page 3
FirstName LastName
        You may contact Christie Wong, Staff Accountant, at 202-551-3684, or
Robert S.
Littlepage, Accounting Branch Chief, at 202-551-3361, if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Staff
Attorney, at 202-551-3415, or Kathleen Krebs, Special Counsel, at 202-551-3350,
with any other
questions.




                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Telecommunications
cc:      Scott Doney
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