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CORRESP Filing

XTI Aerospace, Inc.
Date: June 17, 2025 · CIK: 0001529113 · Accession: 0001213900-25-055283

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File numbers found in text: 333-287989

Date
June 17, 2025
Author
Scott Pomeroy
Form
CORRESP
Company
XTI Aerospace, Inc.

Letter

XTI Aerospace, Inc.

8123 InterPort Blvd., Suite C

Englewood, Colorado 80112

June 17, 2025

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

RE: XTI Aerospace, Inc.

Registration Statement on Form S-1

Filed June 12, 2025

File No. 333-287989

Acceleration Request

Requested Date: Wednesday, June 18, 2025

Requested Time: 5:00 p.m. Eastern Time

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant (the " Registrant ") hereby requests that the Securities and Exchange Commission (the " Commission ") take appropriate action to cause the above-referenced Registration Statement on Form S-1 (File No. 333-287989) (the " Registration Statement ") to become effective on Wednesday, June 18, 2025, at 5:00 p.m. Eastern Time, or as soon thereafter as possible, or at such later time as the Registrant or its outside counsel, Mitchell Silberberg & Knupp LLP, may orally request via telephone call to the staff.

Once the Registration Statement has been declared effective, please orally confirm that event with our outside counsel by calling Blake Baron at (917) 546-7709.

Very truly yours,
XTI Aerospace, Inc.

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CORRESP
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 filename1.htm

 XTI Aerospace, Inc.

 8123 InterPort Blvd., Suite C

 Englewood, Colorado 80112

 June 17, 2025

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 RE:
 XTI Aerospace, Inc.

 Registration Statement on Form S-1

 Filed June 12, 2025

 File No. 333-287989

 Acceleration Request

 Requested Date: Wednesday, June 18, 2025

 Requested Time: 5:00 p.m. Eastern Time

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities Act of 1933, as amended,
the undersigned registrant (the " Registrant ") hereby requests that the Securities and Exchange Commission (the " Commission ")
take appropriate action to cause the above-referenced Registration Statement on Form S-1 (File No. 333-287989) (the " Registration
Statement ") to become effective on Wednesday, June 18, 2025, at 5:00 p.m. Eastern Time, or as soon thereafter as possible, or
at such later time as the Registrant or its outside counsel, Mitchell Silberberg & Knupp LLP, may orally request via telephone call
to the staff.

 Once the Registration Statement
has been declared effective, please orally confirm that event with our outside counsel by calling Blake Baron at (917) 546-7709.

 Very truly yours,

 XTI Aerospace, Inc.

 By:
 /s/ Scott Pomeroy

 Scott Pomeroy

 Chief Executive Officer