December 18, 2019 Russell C. Horowitz Executive Chairman and Co-CEO Marchex, Inc. 520 Pike Street, Suite 2000 Seattle, WA 98101 Re: Marchex, Inc. Registration Statement on Form S-3 Filed December 12, 2019 File No. 333-235471 Dear Mr. Horowitz: 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 Daniel Morris at (202) 551-3314 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services