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CORRESP
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    December
    16, 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 December 14, 2022, with respect to the Issuer’s Offering Statement on Form 1-A (File No. 024-12067), filed with
the SEC on December 9, 2022. This letter is being submitted contemporaneously with the filing of the Second Amendment (the “Second
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.

Investor
Perks, page 26

    1.
    We
                                            note your belief that the bonus shares “alter the sales price and cost basis of the
                                            securities in this offering.” Please revise your disclosure of the price
                                            per security to reflect the bonus shares. Refer to Rule 251(a)(1). Additionally, please ensure
                                            that your disclosure describes the differentiated pricing or terms in the summary section.

Issuer
Response: The Company acknowledges the Staff’s comment and has revised disclosures on page 26 of the Revised Offering Circular.

    2.
    You
                                            state that the investor perks are subject to availability and that the Company reserves the
                                            right to change these perks at any time as needed. Please provide the legal basis for your
                                            ability to change or eliminate the perks. Describe how any such perks would not be “available”
                                            and the circumstances under which the Company would change these perks. Disclose whether
                                            or not the Company retains the right to make these changes after it has accepted
                                            investor subscriptions.

Issuer
Response: The Issuer has eliminated this language on page 26 and will not change or modify the perks after beginning to accept investor
subscriptions in the contemplated offering.

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