United States securities and exchange commission logo March 12, 2021 John Pence Chief Financial Officer Asure Software, Inc. 3700 N. Capital of Texas Hwy #350 Austin, Texas 78746 Re: Asure Software, Inc. Registration Statement on Form S-3 Filed March 11, 2021 File No. 333-254138 Dear Mr. Pence: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rule 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 Alexandra Barone, Staff Attorney, at (202) 551- 8816 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Katheryn A. Gettman, Esq.