Mail Stop 3561                                              September 10, 2018


Mr. Ronald Cogburn
Chief Executive Officer
Exela Technologies, Inc.
2701 E. Grauwyler Rd.
Irving, TX 75061

       Re:    Exela Technologies, Inc.
              Form 10-K for Fiscal Year Ended December 31, 2017
              Filed March 16, 2018
              File No. 001-36788

Dear Mr. Cogburn:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for Fiscal Year Ended December 31, 2017

Business

Overview of Revenues, page 6

   1. We note the description of your business model on pages 5 and 6, under
this heading,
      within Management's Discussion and Analysis of Financial Condition and
Results of
      Operations, and in the footnotes to your financial statements. We further
note that the
      graphic on page 6 lists a large number of services that you provide, and
you similarly list
      a large number of services that you provide when describing your ITPS
segment under
      this heading. To make your disclosures about your business more
meaningful, please tell
      us and revise future filings to more clearly disclose the most
significant services provided
      by the ITPS segment. The current disclosure does not convey the relative
significance of
      each service offered and may lead a reader to believe certain service
offerings are more
      material to your revenue than they actually are. For each solution or
service offered by
      the ITPS segment that materially contributes to your revenue, please tell
us in more detail
 Mr. Ronald Cogburn
Exela Technologies, Inc.
September 10, 2018
Page 2

        and revise future filings to more clearly disclose what comprises that
solution or service
        and what your role is in providing that solution or service to your
customer.

        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 Sondra Snyder, Staff Accountant at (202) 551-3332 or me
at (202) 551-
3737 with any questions.


                                                             Sincerely,

                                                             /s/ Jennifer
Thompson

                                                             Jennifer Thompson
                                                             Accounting Branch
Chief
                                                             Office of Consumer
Products