August 15, 2024

Glenn Sanford
Founder, Chief Executive Officer and Chair of the Board
eXp World Holdings, Inc.
2219 Rimland Drive, Suite 301
Bellingham, WA 98226

       Re: eXp World Holdings, Inc.
           Definitive Proxy Statement on Schedule 14A
           Filed March 27, 2024
           File No. 001-38493
Dear Glenn Sanford:

      We have limited our review of your most recent definitive proxy statement
to those issues
we have addressed in our comment(s).

       Please respond to this letter by providing the requested information
and/or confirming that
you will revise your future proxy disclosures in accordance with the topics
discussed below. If
you do not believe a comment applies to your facts and circumstances, please
tell us why in your
response.

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

Definitive Proxy Statement on Schedule 14A
Pay Versus Performance, page 41

1.     The Company-Selected Measure should, in your assessment, "represent the
most
       important financial performance measure (that is not otherwise required
to be disclosed in
       the table) used by [you] to link compensation actually paid to [your]
named executive
       officers, for the most recently completed fiscal year, to company
performance.    See Item
       402(v)(2)(vi) of Regulation S-K. It appears that the Company-Selected
Measure data
       provided in your pay versus performance table has been measured across
more than one
       fiscal year, since the measurement periods start and end in September,
rather than
       December. Please ensure that the quantified performance information
regarding your
       Company-Selected Measure is not measured over a multi-year period. Refer
to Item
       402(v)(2)(vi) of Regulation S-K and Regulation S-K Compliance and
Disclosure
       Interpretation 128D.11.
 August 15, 2024
Page 2
2.     We note disclosure in footnote 9 to your pay versus performance table
that due to
       administrative errors, you adjusted the Summary Compensation Table for
some of your
       NEOs for 2021 and 2022 and you overstated the    Compensation Actually
Paid to PEO
       for 2021 and overstated the    Average Compensation Actually Paid to
Non-PEO NEOs
       for 2022. We also note that you limited your footnote disclosure to the
most recent fiscal
       year, but you state you also provide such footnote disclosure for 2022
and 2021 in
       footnotes 2 and 4 to your pay versus performance table. Regulation S-K
Compliance and
       Disclosure Interpretation 128D.03 contemplates omitting footnote
disclosure for all years
       other than the most recent fiscal year unless the prior years
footnote disclosure would be
       material to an investor   s understanding of the information reported in
the pay versus
       performance table for the most recent fiscal year, or of the
relationship disclosure
       provided under Item 402(v)(5) of Regulation S-K. Please tell us how you
concluded that
       you were not required to provide footnote disclosure for years other
than the most recent
       fiscal year in light of the revisions to your Summary Compensation Table
and
       compensation actually paid amounts for 2021 and 2022.

        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 Conlon Danberg at 202-551-4466 or Daniel Crawford at
202-551-7767
with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Disclosure Review
Program
cc:   Ali Nardali, Esq.