UNITED STATES
                                 SECURITIES AND EXCHANGE COMMISSION
                                             WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                                      April 19,
2019


  Jeffrey E. Eberwein
  Chief Executive Officer
  Hudson Global, Inc.
  53 Forest Avenue
  Old Greenwich, CT 06870

          Re:     Hudson Global, Inc.
                  DEFA14A filing made under cover of Schedule 14A
                  Filed on April 18, 2019 by Hudson Global, Inc.
                  File No. 001-38704

  Dear Mr. Eberwein,
          We have reviewed the above-captioned filing, and have the following
comment. Our
  comment may ask for additional information so that we may better understand
the disclosure.

           Please respond to this letter by amending the filing and/or by
providing the requested
  information. If you do not believe our comment applies to your facts and
circumstances, and/or do
  not believe an amendment is appropriate, please tell us why in a written
response.
        After reviewing any amendment to the filing and any information
provided in response to this
  comment, we may have additional comments.

  Schedule 14A | Definitive Additional Materials

  1. The cover page has characterized the submission as "Definitive Additional
Materials" instead
     of "Definitive Proxy Statement," and the Schedule 14A has been altered in
comparison to
     what form the U.S. Securities and Exchange Commission codified at Rule
14a-101. As a
     result of this apparent elective edit, the entry space for the amendment
number has been
     deleted. The substantive content of the submission characterizes the
filing as a "Supplement
     to the Proxy Statement" and further represents that the supplement revises
the definitive
     proxy statement. Please advise us, with a view toward revised disclosure,
why the
     submission was not identified as Amendment No. 1 to the Definitive Proxy
Statement and
     designated on EDGAR using the header tag DEFR14A. To the extent no revised
submission
     is made, please provide us with a brief legal analysis explaining why
Hudson Global believes
     the existing submission lawfully amends the definitive proxy statement as
represented in bold
     typeface when it appears to have been filed pursuant to Rule 14a-6(c).

         We remind you that the registrant is responsible for the accuracy and
adequacy of its
  disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
 Jeffrey E. Eberwein
Hudson Global, Inc.
April 19, 2019
Page 2

        You may contact me at (202) 551-3266 with any questions.


                                                         Sincerely,

                                                         /s/ Nicholas P. Panos

                                                         Nicholas P. Panos
                                                         Senior Special Counsel
                                                         Office of Mergers &
Acquisitions

cc:     Lawrence S. Elbaum, Esq.