This question is looking for factors of 38 with counters being a factor greater ten and the number of bags being the factor that multiplies the counters to get 38. First, find the factors of 38.
1 x 38 = 38
2 x 19 = 38
Since the problem says bags with an s, we can know that there has to be more than one bag. That leaves us with 2 x 19.