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CORRESP
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    December 9, 2022

Division
of Corporation Finance

U.S.
Securities & Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Attn:
    Austin
    Pattan, Staff Attorney

    Joshua
    Shainess, Legal Branch Chief

    RE:
    THUMZUP MEDIA Corp

    Offering Statement on Form
    1-A

    Filed November 17, 2022

    File No. 024-12067

To
the Division of Corporation Finance:

This
letter is submitted on behalf of THUMZUP MEDIA Corp, a Nevada corporation (the “Issuer”), in response to comments received
from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”)
in a letter dated November 30, 2022, with respect to the Issuer’s Offering Statement on Form 1-A (File No. 024-12067), filed with
the SEC on November 17, 2022. This letter is being submitted contemporaneously with the filing of the First Amendment (the “First
Amendment”) to the Offering Circular (the “Offering Circular”) containing changes made in response to the Staff’s
comments and for the purpose of updating and revising certain information in the Offering Circular.

For
ease of reference, each Staff comment contained in the Comment Letter is reprinted below in bold and followed by the corresponding response
of the Issuer.

Plan
of Distribution and Selling Shareholders, page 24

    1.
    We note your statement
    that Dalmore Group will not be engaged as a placement agent but will “assist with the share sales in exchange for a 1% commission.”
    Please clarify the role of the Dalmore Group and provide support for your belief that Dalmore Group is not acting as a placement
    agent.

Issuer
Response: Pursuant to the Broker-Dealer Agreement between the Dalmore Group and the Issuer, the Dalmore Group will perform the following
exclusive list of services, which does not include the introduction of potential Investors to the Issuer:

 i. Review
                                            Investor information, including KYC (Know Your Customer) data, AML (Anti-Money Laundering),
                                            OFAC compliance background checks (it being understood that KYC and AML processes may be
                                            provided by a qualified third party);

 ii. Review
                                            each Investor’s subscription agreement to confirm such Investor’s participation
                                            in the Offering, and provide confirmation of completion of such subscription documents to
                                            Client;

 iii. iii.
                                            Contact and/or notify the issuer, if needed, to gather additional information or clarification
                                            on an Investor;

 iv. Keep
                                            Investor information and data confidential and not disclose to any third-party except as
                                            required by regulatory agencies or in our performance under this Agreement (e.g. as needed
                                            for AML and background checks);

 v. Coordinate
                                            with third party providers to ensure adequate review and compliance;

 vi. Provide,
                                            or coordinate the provision by a third party, of an “invest now” payment processing
                                            mechanism, including connection to a qualified escrow agent.

General

    2.
    We note your stated
    intention to offer bonus shares to early investors, while conducting your offering to the public at a fixed price. Please provide
    your analysis as to the company’s eligibility to conduct such an offering under Regulation A. In this regard, it appears that
    the use of bonus shares in this manner would constitute a delayed primary offering. Refer to Securities Act Rule 251(d)(3)(F)(ii).

Issuer
Response: The Issuer has modified the proposed Investor Perks program on page 26 to eliminate the offer of Bonus Shares to the first
400 subscribers within 60 days of qualification to encourage early investment. The Issuer believes this change allows for the use of
the remaining Bonus Shares in a manner that would not constitute a delayed primary offering.

    3.
    We note your disclosure
    that the impetus for issuing bonus shares is to reach the requisite number of shareholders and shareholder’s equity to meet
    the listing criteria of a national exchange. Please provide more detail regarding the company’s intention to uplist to a national
    exchange. If qualifying for listing on a national exchange is a condition to this offering, please include the appropriate disclosures
    on the cover page. Additionally, revise the summary and risk factors section to include cautionary language highlighting that the
    company may never meet the listing criteria of a national exchange, and that investors could be left holding illiquid securities.

Issuer
Response: As described above, the Issuer has modified the proposed Investor Perks program to eliminate the offer of Bonus Shares
to the first 400 subscribers within 60 days of qualification to encourage early investment. Furthermore, the Issuer has deleted the language
stating the Issuer’s belief that the use of the Bonus Program in this manner “will result in the Company having the requisite
number of shareholders and shareholder’s equity to meet the listing criteria of a national exchange.” Because qualifying
for listing on a national exchange is not a condition of this offering, no additional disclosure in this regard has been added to the
cover page. The Issuer has also the revised the summary on page 2 and risk factor section on page 15 to include cautionary language highlighting
that the Company may never meet the listing criteria of a national exchange and that Investors could be left holding illiquid securities.
This revision includes the following additional risk factor:

There
can be no assurance that our Common Stock will ever be approved for listing on a national securities exchange. Failure
to develop or maintain an active trading market could negatively affect the value of our Common Stock and make it difficult or impossible
for investors to sell their shares in a timely manner.

There
is currently very limited trading of our Common Stock, and an active trading market may never develop. Our Common Stock is quoted on
the OTCQB tier of the OTC Markets. The OTCQB tier of the OTC Markets is a thinly traded market and lacks the liquidity of certain other
public markets with which some investors may have more experience. While
we remain determined to work towards getting our securities listed on a national exchange, there can be no assurance that this will occur.
As a result we may never develop an active trading market for our securities which may limit our investors’ ability to liquidate
their investments.

The
Issuer respectfully believes that the information contained herein is responsive to the Staff Comment Letter. Please feel free to contact
me at the above number for any questions related to this letter. If you need any additional information or have any follow up questions,
please feel free to contact Joseph Nunziata of Sichenzia Ross Ference LLP at (212) 930-9700.

    Sincerely,

    By:
    /s/ Robert
    Steele

    Name:
    Robert Steele

    Title:
    Chief Executive Officer