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Correspondence 0001628280-24-031366 from SMITH MICRO SOFTWARE, INC. (SMSI)

SMITH MICRO SOFTWARE, INC.
Date: July 8, 2024 · CIK: 0000948708 · Accession: 0001628280-24-031366

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File numbers found in text: 333-280542

Date
July 8, 2024
Author
James M. Kempton
Form
CORRESP
Company
SMITH MICRO SOFTWARE, INC.

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance, Office of Technology Attention: Uwem Bassey; Matt Derby Registration Statement on Form S-1 Filed June 27, 2024 File No. 333-280542 Request for Acceleration of Effectiveness

Dear Messrs. Bassey and Derby:

Pursuant to Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, Smith Micro Software, Inc. (the “Company”) hereby respectfully requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-280542), so that it may become effective on July 10, 2024, at 5:00 p.m., Eastern Time, or as soon thereafter as practicable. The Company hereby authorizes Brian Novosel, Esq., and Jennifer Minter, Esq. of Buchanan Ingersoll & Rooney PC, counsel to the Company, to orally modify or withdraw this request for acceleration.

Please contact Brian Novosel of Buchanan Ingersoll & Rooney PC, counsel to the Company, at (412) 562-5266, or in his absence, Jennifer Minter at (412) 562-8444, to provide notice of effectiveness, or if you have any other questions or concerns regarding this matter.

Sincerely,
Smith Micro Software, Inc.

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CORRESP
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Document

July 8, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance, Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

Attention:  Uwem Bassey; Matt Derby

Re: Acceleration Request of Smith Micro Software, Inc.

 Registration Statement on Form S-1

 Filed June 27, 2024

 File No. 333-280542

 Request for Acceleration of Effectiveness

Dear Messrs. Bassey and Derby:

Pursuant to Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, Smith Micro Software, Inc. (the “Company”) hereby respectfully requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-280542), so that it may become effective on July 10, 2024, at 5:00 p.m., Eastern Time, or as soon thereafter as practicable. The Company hereby authorizes Brian Novosel, Esq., and Jennifer Minter, Esq. of Buchanan Ingersoll & Rooney PC, counsel to the Company, to orally modify or withdraw this request for acceleration.

Please contact Brian Novosel of Buchanan Ingersoll & Rooney PC, counsel to the Company, at (412) 562-5266, or in his absence, Jennifer Minter at (412) 562-8444, to provide notice of effectiveness, or if you have any other questions or concerns regarding this matter.

Sincerely,

Smith Micro Software, Inc.

By: /s/ James M. Kempton

 James M. Kempton

 Vice President, Chief Financial Officer

and Treasurer

cc: William W. Smith, Jr., Chairman of the Board, President and Chief Executive Officer