Exhibit 10.39

AMENDMENT NO. 4 TO EMPLOYMENT AGREEMENT

This Amendment No. 4 (the “Amendment”) to the Employment Agreement is made and entered into as of the last date that appears below the Parties’ signature lines on the last page of this Amendment (the “Effective Date”), by and between Kevin Brian Cox, an individual, (the “Executive”) and SurgePays, Inc. (the “Company”) (each individually, a “Party,” collectively, the “Parties”).

WHEREAS, the Parties entered into that certain Employment Agreement, dated December 22, 2023, as amended from time to time (collectively, the “Employment Agreement”);

WHEREAS, all capitalized terms used in this Amendment that are not defined in this Amendment shall have the same meaning as in the Employment Agreement, and all section references are to sections to the Employment Agreement;

WHEREAS, pursuant to the Employment Agreement and subject to certain terms and conditions, the Company is obligated to pay a cash bonus to executive for 2025 in the amount of $870,000.00 (the “Bonus”);

WHEREAS, the Parties wish to postpone the payment of the Bonus until October 1, 2026; and

WHEREAS, the Executive desires to be employed by the Company on the terms and conditions in the Employment Agreement as amended by this Amendment.

NOW, THEREFORE, in consideration of the mutual covenants, promises, and obligations set forth herein, and good and valuable consideration, the receipt and adequacy of which are hereby acknowledged, the Parties agree that the Employment Agreement is hereby amended as follows:

The following sentence shall be added to Section 3.02:

“Executive’s Bonus for the year ending December 31, 2025 shall be payable on October 1, 2026.”

[Signature Page Follows]

IN WITNESS WHEREOF, the Parties hereto have executed this Amendment to the Employment Agreement as of the dates set forth below.