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                                                            February 12, 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 February 5, 2025
           FIle No. 000-55984
Dear Alvaro Quintana Cardona:

       We have reviewed your February 5, 2025 response to our comment letter
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.
Unless we note otherwise, any references to prior comments are to comments in
our January
27, 2025 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 your response to prior comment 1 and your response to comment 2
in your
       letter dated December 4, 2024. Disclose as part of your revenue
recognition policy
       disclosure your basis for reporting revenue on a gross basis. In your
response to this
       comment, please provide us example disclosure of what you will provide
in future
       filings.
2.     We note your response to prior comment 1. Please expand your revenue
       recognition policy, business, and MD&A disclosures in future filings so
that the
       nature of your revenue generating business including your customers, the
services you
       provide, your performance obligations, the vendor networks you utilize,
and the cash
 February 12, 2025
Page 2

       flows in your arrangements are wholly transparent to readers, consistent
with what
       was communicated to us in your letters dated February 5, 2025 and
December 4,
       2024. In this regard, an illustration of the usage and provision of
services similar to
       what you provided to us in your response may be helpful. In your
response to this
       comment please provide us with examples of the disclosures you will
provide.
3.     We note in your response to prior comment 1 you refer to an
answer-seizure ratio
       ("ASR"). Please tell us whether management uses key performance
indicators or
       usage metrics, such as ASR, in managing the business. If so, please
disclose and
       discuss in future filings or explain why you believe the metrics would
not be key
       indicators of the Company   s operating performance. Refer to Item
303(a) of
       Regulation S-K and Section III.B.1 of SEC Release No. 33-8350.
       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
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