January 2, 2020 Scipio Maximus Carnecchia Chief Executive Officer Mitek Systems, Inc. 600 B Street, Suite 100 San Diego, CA 92101 Re: Mitek Systems, Inc. Registration Statement on Form S-3 Filed December 20, 2019 File No. 333-235662 Dear Mr. Carnecchia: 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 Edwin Kim, Attorney-Advisor, at 202-551-3297 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Carl Sanchez, Esq.