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SEC Company Response from Phunware, Inc. (PHUN) (CIK 0001665300) (PHUN) — Aug 18, 2016

Phunware, Inc. (PHUN) (CIK 0001665300)
Date: Aug. 18, 2016 · CIK: 0001665300 · Accession: 0001213900-16-016188

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File numbers found in text: 333-212377

Date
August 18, 2016
Author
/s/ Prokopios (Akis) Tsirigakis
Form
CORRESP
Company
Phunware, Inc. (PHUN) (CIK 0001665300)

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Re: Stellar Acquisition III Inc. Registration Statement on Form S-1 Filed June 30, 2016, as amended File No. 333-212377

Dear Ms. Ravitz:

On August 12, 2016, Stellar Acquisition III Inc. (the “Company”) requested acceleration of the effective date of the above-referenced Registration Statement so that it would become effective at 4:00 p.m. (New York time) on August 16, 2016, or as soon thereafter as practicable. We hereby withdraw our request until further notice.

Very truly yours,
By:
/s/ Prokopios (Akis) Tsirigakis

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CORRESP
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filename1.htm

Stellar Acquisition III Inc.

90 Kifissias Avenue

Maroussi 15125

Athens, Greece

    August 18, 2016

VIA EDGAR

Amanda Ravitz

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re:  Stellar Acquisition III Inc.

    Registration Statement on Form S-1

    Filed June 30, 2016, as amended

    File No. 333-212377

Dear Ms. Ravitz:

On August 12, 2016, Stellar Acquisition III
Inc. (the “Company”) requested acceleration of the effective date of the above-referenced Registration Statement so
that it would become effective at 4:00 p.m. (New York time) on August 16, 2016, or as soon thereafter as practicable. We hereby
withdraw our request until further notice.

    Very truly yours,

    By:
    /s/ Prokopios (Akis) Tsirigakis

    Prokopios (Akis) Tsirigakis
co-Chief Executive Officer

cc:  Ellenoff Grossman & Schole LLP

    Loeb & Loeb LLP