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CORRESP Filing

XTI Aerospace, Inc.
Date: Aug. 11, 2025 · CIK: 0001529113 · Accession: 0001213900-25-074133

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File numbers found in text: 333-289194

Date
August 11, 2025
Author
Scott Pomeroy
Form
CORRESP
Company
XTI Aerospace, Inc.

Letter

XTI Aerospace, Inc.

8123 InterPort Blvd., Suite C

Englewood, Colorado 80112

August 11, 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-3 (File No. 333-289194)

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-3 (File No. 333-289194) (the " Registration Statement ") to become effective on Tuesday, August 12, 2025, at 4:30 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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 XTI Aerospace, Inc.

 8123 InterPort Blvd., Suite C

 Englewood, Colorado 80112

 August 11, 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-3 (File No. 333-289194)

 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-3 (File No. 333-289194) (the " Registration Statement ") to become effective on Tuesday, August 12,
2025, at 4:30 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