| 1.     |        | I have reviewedthis Quarterly Report on Form 10-Q for the quarter ended September30, 2016 of MobileSmith, Inc.;                                                                                                                                                                                                                       |
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| 2.     |                                 | Based on myknowledge, this report does not contain any untrue statement of amaterial fact or omit to state a material fact necessary to makethe statements made, in light of the circumstances under which suchstatements were made, not misleading with respect to the periodcovered by this report;                                 |
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| 3.     |                                 | Based on myknowledge, the financial statements, and other financialinformation included in this report, fairly present in all materialrespects the financial condition, results of operations and cashflows of the registrant as of, and for, the periods presented inthis report;                                                    |
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| 4.     |                                 | Theregistrant’s other certifying officer and I are responsiblefor establishing and maintaining disclosure controls and procedures(as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) andinternal control over financial reporting (as defined in ExchangeAct Rules 13a-15(f) and 15d-15(f)) for the registrant andhave: |
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|   |                                 | a)                                                                                                                                                                                                                                                                                                                                    |        | Designed suchdisclosure controls and procedures, or caused such disclosurecontrols and procedures to be designed under our supervision, toensure that material information relating to the registrant,including its consolidated subsidiaries, is made known to us byothers within those entities, particularly during the period inwhich this report is being prepared; |
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|   |                                 | b)                                                                                                                                                                                                                                                                                                                                    |   | Designed suchinternal control over financial reporting, or caused such internalcontrol over financial reporting to be designed under oursupervision, to provide reasonable assurance regarding thereliability of financial reporting and the preparation of financialstatements for external purposes in accordance with generallyaccepted accounting principles; |
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|   |                                 | c)                                                                                                                                                                                                                                                                                                                                    |   | Evaluated theeffectiveness of the registrant’s disclosure controls andprocedures and presented in this report our conclusions about theeffectiveness of the disclosure controls and procedures, as of theend of the period covered by this report based on such evaluation;and |
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|   |                                 | d)                                                                                                                                                                                                                                                                                                                                    |   | Disclosed in thisreport any change in the registrant’s internal control overfinancial reporting that occurred during the registrant’smost recent fiscal quarter (the registrant’s fourth fiscalquarter in the case of an annual report) that has materiallyaffected, or is reasonably likely to materially affect, theregistrant’s internal control over financialreporting. |
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| 5.     |                                 | Theregistrant’s other certifying officer and I have disclosed,based on our most recent evaluation of internal control overfinancial reporting, to the registrant’s auditors and theaudit committee of the registrant’s board of directors (orpersons performing the equivalent functions):                       |
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|   |                                 | a)                                                                                                                                                                                                                                                                                                                                    |   | All significantdeficiencies and material weaknesses in the design or operation ofinternal control over financial reporting which are reasonablylikely to adversely affect the registrant’s ability torecord, process, summarize and report financial information;and |
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|   |                                 | b)                                                                                                                                                                                                                                                                                                                                    |   | Any fraud, whetheror not material, that involves management or other employees whohave a significant role in the registrant’s internal controlover financial reporting. |

| /s/  GlebMikhailov                                                |   |
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| GlebMikhailov                                                               |   |
| Chief FinancialOfficer(Principal Financialand Accounting Officer) |   |