SEC Company Response from Phunware, Inc. (PHUN) (CIK 0001665300) (PHUN) — Nov 13, 2018

Phunware, Inc. (PHUN) (CIK 0001665300)
Date: Nov. 13, 2018 · CIK: 0001665300 · Accession: 0001213900-18-015457

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File numbers found in text: 333-224227

Date

November 13, 2018

Author

/s/ George Syllantavos

Form

CORRESP

Company

Phunware, Inc. (PHUN) (CIK 0001665300)

Letter

VIA EDGAR Division of Corporation Finance Re: Stellar Acquisition III Inc. Registration Statement on Form S-4 Filed April 11, 2018, as amended File No. 333-224227

Dear Ms. Ayoola:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Stellar Acquisition III Inc. hereby requests acceleration of the effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 p.m. Eastern Time on November 13, 2018, or as soon as thereafter practicable.

Very truly yours,
/s/ George Syllantavos

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CORRESP
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filename1.htm

STELLAR ACQUISITION III INC.

90 Kifissias Avenue

Maroussi Athens, Greece

November 13, 2018

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn: Folake Ayoola, Special Counsel

    Re:
    Stellar Acquisition III Inc.

    Registration Statement on Form S-4

    Filed April 11, 2018, as amended

    File No. 333-224227

Dear Ms. Ayoola:

Pursuant to Rule 461 promulgated under
the Securities Act of 1933, as amended, Stellar Acquisition III Inc. hereby requests acceleration of the effectiveness of the above
referenced Registration Statement so that it will become effective at 4:00 p.m. Eastern Time on November 13, 2018, or as soon as
thereafter practicable.

    Very truly yours,

    /s/ George Syllantavos

    George Syllantavos

    Co-Chief Executive Officer, Chief Financial Officer (Principal Financial and Accounting Officer

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