<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                           January 27, 2025

Alvaro Quintana Cardona
Chief Financial Officer
iQSTEL Inc
300 Aragon Avenue, Suite 375
Coral Gables, FL 33134

       Re: iQSTEL Inc
           Form 10-K for the Year Ended December 31, 2023
           Response dated December 4, 2024
           FIle No. 000-55984
Dear Alvaro Quintana Cardona:

        We have reviewed your December 4, 2024 response to our comment letter
and have
the following comment.

       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.
Unless we note otherwise, any references to prior comments are to comments in
our
November 8, 2024 letter.

Form 10-K for the Year Ended December 31, 2023
Audited Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-11

1.
       We note in your response to prior comment 2 you identified several
services
       including "International Voice Termination for carriers" and
International SMS
       termination.    We also note costs of revenue    primarily consist of
usage charges for
       calls terminated in vendors    networks." Please explain to us the
Company   s role in
       these service arrangements and clarify if the Company is as an
intermediary for calls
       terminated on another vendors    network. Also, please explain:
           How the Company controls these services immediately prior to the
service being
           transferred to the customer when it appears these services are
provided on another
 January 27, 2025
Page 2

           entity   s network in an instant.
             We note with respect to "International Voice Termination for
carriers" and
              International SMS termination    services you said the Company is
primarily
           responsible for fulfilling the promise to provide the specified
service. If true,
           please confirm that it is understood by your customers that the
Company is not
           physically capable of providing termination services on another
entities network.
             Tell us if the terms of your customer contracts or your other
communications (for
           example, marketing materials) with your customers indicate that the
Company or
           a third party is responsible for providing the call termination
service.
             Tell us if for a particular call, there are several vendor
networks to choose from
           and if the Company has discretion in selecting which vendor network
to utilize to
           fulfill an end consumer order.
             Please also clarify for us the cash flows in these arrangements.
It is unclear if you
           first collect from customers and then share a portion of the revenue
with the
           network vendors or if your customers remit the net proceeds to you
after
           deducting the third party network vendors    share.


       Please contact Anastasia Kaluzienski at 202-551-3685 or Robert
Littlepage at 202-
551-3361 if you have questions regarding comments on the financial statements
and related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
</TEXT>
</DOCUMENT>
