March 26, 2020

James DeSocio
Chief Executive Officer
Intellinetics, Inc.
2190 Dividend Drive
Columbus, Ohio 43228

       Re: Intellinetics, Inc.
           Information Statement on Schedule 14C
           Filed March 17, 2020
           File No. 000-31671

Dear Mr. DeSocio:

       We have reviewed your filing 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Information Statement on Schedule 14C

Approval of an Amendment to our Articles of Incorporation...
Reasons for the Reverse Split and Charter Amendments

1.    We note your statement that the reverse split and charter amendments were
necessary to
      effectuate the acquisition of Graphic Sciences, Inc. Therefore, it
appears that you must
      provide the disclosures required by Item 14 of Schedule 14A regarding the
transaction.
      Refer to Note A of Schedule 14A as well as Item 1 of Schedule 14C, which
incorporates
      the disclosure requirements of Schedule 14A. Please revise to provide all
such
      information or, alternatively, explain why you believe such disclosure is
not required.
        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.

       You may contact Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in
his absence,
 James DeSocio
Intellinetics, Inc.
March 26, 2020
Page 2

Jan Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you
require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.



                                                          Sincerely,
FirstName LastNameJames DeSocio
                                                          Division of
Corporation Finance
Comapany NameIntellinetics, Inc.
                                                          Office of Technology
March 26, 2020 Page 2
cc:       Erin C. Herbst, Esq.
FirstName LastName