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June 3, 2024
Jeremy J. Welter
Reporting Person
Ashford Inc.
1101 Excalibur Blvd.
Lewisville, TX 75056
Re:Ashford Inc.
Scheduled 13D Filed by Jeremy J. Welter
Filed April 11, 2024
File No. 005-88416
Dear Jeremy J. Welter:
            We have reviewed the above-captioned filing and have the following comments.
            Please respond to this letter by amending the filing or by providing the requested
information. If you do not believe our comments apply to your facts and circumstances or that an
amendment is appropriate, please advise us why in a response letter.
            After reviewing any amendment to the filing and any information provided in response to
these comments, we may have additional comments. All defined terms used herein have the
same meaning as in your filing, unless otherwise indicated.
Schedule 13D Filed April 11, 2024
General
1.We note the date of the event reported as requiring the filing of the Statement was April 2,
2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule 13D within
five business days after the date beneficial ownership of more than five percent of a class
of equity securities specified in Rule 13d-1(i)(1) was acquired. Based on the April 2, 2024
event date, the Schedule 13D submitted on April 11, 2024 was not timely filed. Please
advise us why the Schedule 13D was not filed within the required five business days after
the date of the acquisition.
2.While footnote 1 to the cover page and similar disclosure under Item 5(a) of the Schedule
13D indicate that 68 Common Units are included in the Common Stock reported as
beneficially owned by the Reporting Person, it does not appear that such Common Units
have been included in the reported 194,615 shares of Common Stock. Please revise or
advise.

 FirstName LastNameJeremy J. Welter
 Comapany NameAshford Inc.
 June 3, 2024 Page 2
 FirstName LastName
Jeremy J. Welter
Ashford Inc.
June 3, 2024
Page 2
Item 2, page 3
3.We note the disclosure provided in response to Item 2(c) of Schedule 13D that "[t]he
Reporting Person is currently self-employed." As required by the terms of Item 2(c),
please revise to specify the Reporting Person's "present principal occupation or
employment and the name, principal business and address of any corporation or other
organization in which such employment is conducted."
Item 3, page 3
4.Item 3 of Schedule 13D requires the beneficial owner to "[s]tate the source and the
amount of funds or other consideration used or to be used in making the purchases"
or "[i]f the securities were acquired other than by purchase, describe the method of
acquisition." The disclosure provided in response to Item 3 does not appear to address this
requirement. The disclosure provided under Item 4, however, indicates that "[t]he shares
of Common Stock beneficially owned by the Reporting Person were acquired as
compensation for his services as an executive officer of the Issuer." Please advise us, with
a view toward revised disclosure, why the cited disclosure from Item 4 was not provided
under Item 3 and why the current disclosure under Item 3 was offered as being responsive.
5.The disclosure explains that the Common Units and the Class 2 LTIP Units are each
ultimately convertible into shares of Common Stock at the option of the Issuer. We also
note that footnote 1 to the cover page and the disclosure under Item 5(a) of the Statement
indicate that 68 Common Units and 162,451 Class 2 LTIP Units are included in the
194,615 shares of Common Stock reported as beneficially owned by the Reporting
Person. Please advise us, with a view toward revised disclosure, why the Reporting Person
should be deemed to be the beneficial owner of the shares of Common Stock underlying
these Common Units and Class 2 LTIP Units if each of these securities is only convertible
into Common Stock at the option of the Issuer. See Exchange Act Rule 13d-3(d)(1)(i).
6.The disclosure under this item indicates that the Reporting Person's "holdings" consist of,
among other things, 68 Common Units and 162,451 Class 2 LTIP Units. If the shares of
Common Stock underlying the Common Units and Class 2 LTIP Units are ultimately
excluded from the aggregate amount of beneficial ownership reported on this Schedule
13D, please also revise this disclosure to avoid the impression that the Common Units and
Class 2 LTIP Units confer a right to acquire beneficial ownership as determined under
Rule 13d-3(d)(1)(i).

 FirstName LastNameJeremy J. Welter
 Comapany NameAshford Inc.
 June 3, 2024 Page 3
 FirstName LastName
Jeremy J. Welter
Ashford Inc.
June 3, 2024
Page 3
            We remind you that the filing person is responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please direct any questions to Shane Callaghan at 202-551-6977 or Nicholas Panos at
202-551-3266.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions