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October 20, 2020

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC. 20549

Attn: Mr. Matthew Derby

    Re:
    Aerkomm Inc.

    Amendment No. 1 to Registration Statement on Form S-1

    Filed July 29, 2020

    File No. 333-237942

Dear Mr. Derby:

We hereby submit
the responses of Aerkomm Inc. (the “Company”) to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) received in a telephonic conference call with
you and Ms. Jan Woo on August 10, 2020, on which Ms. Woo presented comments with respect to the Company’s Registration Statement
on Form S-1 (the “Registration Statement”). Concurrently with the filing of this response letter, we have publicly
filed an amended Registration Statement (the “Registration Statement Amendment”), and the filed Registration
Statement Amendment incorporates our changes as indicated below made in response to Ms. Woo’s comments.

For the convenience
of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company.  Unless
the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to
the Company on a consolidated basis.

Registration Statement on Form S-1

General

 1. Please disclose volume information with respect to the number of shares of the Company’s
common stock that will registered in this offering.

RESPONSE: We have expanded
our disclosure in the Registration Statement Amendment to address the Staff’s additional disclosure requirements stated in
the comment above.

 2. Please include the Company’s six-month financial statements and related disclosure for the
period ending June 30, 2020.

RESPONSE: We have included
the Company’s six-month financial statements and related disclosure for the period ended June 30, 2020 in the Registration
Statement Amendment.

U.S. Securities and Exchange Commission

October 20, 2020

Page 2

 3. Please provide the Exhibit 5.1 legality opinion.

RESPONSE: We have provided
the Exhibit 5.1 legality opinion as a filed exhibit to the Registration Statement Amendment.

If you would like to discuss any of the responses to the Staff’s
comments or if you would like to discuss any other matters, please contact the undersigned at +35679492509 or Louis A. Bevilacqua
of Bevilacqua PLLC at (202) 869-0888, ext. 100.

    Sincerely,

    Aerkomm Inc.

    By:
    /s/ Louis Giordimaina

    Louis Giordimaina

    Chief Executive Officer

 cc: Louis A. Bevilacqua, Esq.