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                          February 9, 2021

       James Thompson
       Chief Executive Officer
       SPYR, Inc.
       8547 E. Arapahoe Rd., #J527
       Greenwood Village, CO 80112

                                                        Re: SPYR, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed February 3,
2021
                                                            File No. 333-252683

       Dear Mr. Thompson:

              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
Lamparski at (202) 551-4695 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Trade & Services
       cc:                                              Tad Mailander