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                          November 13, 2020

       Russell Horowitz
       Executive Chairman and Co-CEO
       Marchex, Inc.
       520 Pike Street, Suite 2000
       Seattle, WA 98101

                                                        Re: Marchex, Inc.
Statement on Form S-3
                                                            Filed November 9,
                                                            File No. 333-249952

       Dear Mr. Horowitz:

              This is to advise you that we have not reviewed and will not
review your registration

               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.


                          Division of Corporation Finance

                          Office of Trade & Services