September 29, 2025

David Wilson
Chief Financial Officer
Powerfleet, Inc.
123 Tice Boulevard
Woodcliff Lake, NJ 07677

       Re: Powerfleet, Inc.
           Form 10-K for the Fiscal Year Ended March 31, 2025
           Response dated September 15, 2025
           File No. 001-39080
Dear David Wilson:

        We have reviewed your September 15, 2025 response to our comment letter
and have
the following comment.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. 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.
Unless we note otherwise, any references to prior comments are to comments in
our August
29, 2025 letter.

Form 10-K for the Fiscal Year Ended March 31, 2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Information, page 40

1.     We have reviewed your response to prior comment 2. We understand that
Fleet
       Complete previously accounted for bundled hardware and service offerings
as a single
       performance obligation and recognized revenue over time. We also
understand that,
       following your acquisition of Fleet Complete, hardware is now a separate
       performance obligation that is satisfied at a point in time. Please more
fully address
       the following:
           Given the differences you noted between Canadian Accounting
Standards for
           Private Enterprises and U.S. GAAP regarding revenue recognition,
explain if
           and how you accounted for hardware deliveries made prior to the
acquisition of
           Fleet Complete in your purchase price allocation and address how
your
 September 29, 2025
Page 2

           valuation and accounting complied with U.S. GAAP;
             Explain if and how you are accounting for hardware deliveries made
prior to the
           acquisition of Fleet Complete in your historical financial
statements and address
           how your accounting complies with U.S. GAAP;
             Explain why you believe a non-GAAP adjustment that adds revenue
meant to
           represent "the proportional invoice value of hardware deliveries
originally shipped
           prior to October 1, 2024" is necessary and appropriate in
calculating certain non-
           GAAP financial measures; and
             We note your non-GAAP adjustment appears to result in an
adjustment to revenue
           in the current period that should/would have been recognized under
U.S. GAAP
           in a prior period. Explain why you believe this adjustment complies
           with Question 100.04 of the Compliance & Disclosure Interpretations
on Non-
           GAAP Financial Measures.

       Please contact Jeff Gordon at 202-551-3866 or Anne McConnell at
202-551-3709 if
you have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing