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CORRESP
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    Dykema
    Gossett PLLC

    111
    E. Kilbourn Ave.

    Suite
    1050

    Milwaukee,
    WI 53202

    www.dykema.com

    Tel:
    414-488-7300

    Andrew
    T. Frost

    Direct
    Dial: (414) 488-7330

    Direct
    Fax: (866) 870-7321

    Email:
    AFrost@dykema.com

May
11, 2023

U.S. Securities and Exchange Commission

Division of Corporate Finance

 Office of Energy & Transportation

 100 F Street, N.E.

Washington, D.C. 20549

Attention:
Michael Purcell and Karina Dorin

    Re:
    Oxbridge
    Acquisition Corp.

    Registration
    Statement on Form S-4

    Filed
    March 27, 2023

    File
    No. 333-270848

Dear
Mr. Purcell and Ms. Dorin:

This
response letter (this “Response”) is submitted on behalf of Oxbridge Acquisition Corp. (the “Company”)
in response to the comments that the Company 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 addressed to Mr. Jay Madhu, dated April 26,
2023 (the “Comment Letter”), with respect to the Company’s registration statement on Form S-4, filed with the
SEC on March 27, 2023 (the “Registration Statement”). The Company is concurrently submitting an amendment to the Registration
Statement (“Amendment No. 1”), which reflects the changes discussed in this Response that the Company made to address
the Staff’s comments and other updates.

For
reference purposes, each of the Staff’s numbered comments from the Comment Letter is set forth in bold text below, followed by
the Company’s response to each comment. All capitalized terms used but not defined in this Response have the meanings ascribed
to them in Amendment No. 1.

The
responses below are based on information provided to Dykema Gossett PLLC by the Company.

California
| Illinois | Michigan | Minnesota | Texas | Washington, D.C. | Wisconsin

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

May
11, 2023

Page
2

Registration
Statement on Form S-4

Summary
Term Sheet, page 5

    1.
    Please
    revise your disclosure to show the potential impact of redemptions on the per share value of the shares owned by non-redeeming shareholders
    by including a sensitivity analysis showing a range of redemption scenarios, including minimum, maximum and interim redemption levels. Please also provide disclosure of the impact of each significant source of dilution, including the Founder Shares, the Oxbridge
    Warrants and the Merger Consideration Warrants at each of the redemption levels detailed in your sensitivity analysis, including
    any needed assumptions.

Response:
In response to the Staff’s comments, the Company has revised its disclosure on page 20 of Amendment No. 1 to provide
disclosure of the potential impact of redemptions on the per share value of the shares owned by non-redeeming shareholders. Further,
in response to the Staff’s comments, the Company has revised its disclosures on pages 6-8 and 75-76 of Amendment
No. 1 to provide disclosure of the impact of each significant source of dilution at each of the redemption levels detailed in the sensitivity
analysis.

    2.
    It
    appears that underwriting fees remain constant and are not adjusted based on redemptions. Revise your disclosure to disclose the
    effective underwriting fee on a percentage basis for shares at each redemption level presented in your sensitivity analysis related
    to dilution.

Response:
The Staff’s comment is noted. The Company confirms to the Staff that the amount of the deferred underwriting commission
payable to the underwriters of the Company’s initial public offering is not required to be adjusted for any shares that are redeemed
in connection with the Company’s initial business combination. The Company has revised the disclosures on page 20 of Amendment
No. 1 to reflect the Staff’s comment.

Q:
May the Sponsor or Oxbridge’s directors, officers, advisors or any of their respective affiliates purchase public shares..., page
15

    3.
    We
    note you disclose that in connection with the shareholder vote to approve the proposed Business Combination, your sponsor, directors,
    officers, advisors or any of their respective affiliates may privately negotiate transactions to purchase public shares and such
    purchases may be effected at purchase prices that are in excess of the per share pro rata portion of the Trust Account. We also note
    your disclosure on page 59 that any such purchases of public shares could be to vote such shares in favor of the Business Combination
    and thereby increase the likelihood of obtaining shareholder approval of the Business Combination. Please provide your analysis on
    how such purchases will comply with Rule 14e-5. To the extent that you are relying on Tender Offer Compliance and Disclosure Interpretation
    166.01 (March 22, 2022), please provide an analysis regarding how it applies to your circumstances.

Response:
In response to the Staff’s comments, and while no privately negotiated transaction are currently contemplated, the Company has
revised its disclosures on pages 16, 65-66, and 123-124 of Amendment No. 1 to appropriately reflect the terms in
reliance on Tender Offer Compliance and Disclosure Interpretation 166.01.

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

May
11, 2023

Page
3

Questions
and Answers About the Business Combination

Q:
Did the Oxbridge Board obtain a third-party valuation or fairness opinion in determining whether or not to proceed with the Business...,
page 15

    4.
    We
    note you disclose that the Oxbridge board obtained a fairness opinion from Stanton Park Advisors LLC. Please provide a clear explanation
    as to the reason why the fairness opinion was obtained, include the fairness opinion as an annex to the proxy statement/prospectus
    and include the information required by Item 1015 of Regulation M-A.

Response: In
response to the Staff’s comments, the Company has revised its disclosures on pages 16 and 116-118 of Amendment No. 1 and
included the fairness opinion as Annex E to the proxy statement/prospectus.

Q:
How will our Sponsor, directors and officers vote?, page 16

    5.
    We
    note your disclosure that your sponsor, directors and officers, who own approximately [68.83]% of your issued and outstanding Class
    A and Class B Ordinary Shares, have agreed to vote such shares in favor of the Business Combination and the other Proposals. Please
    revise your disclosure to discuss whether any of the Class A Ordinary Shares would need to be voted in favor of the Business Combination
    in order for the Business Combination to be approved. In that regard, we note your disclosure on page 51 that, if only the minimum
    amount of shares needed to establish a quorum are present and all such shares are actually voted on the Business Combination Proposal,
    none of the outstanding Class A Ordinary Shares would need to be voted in favor of the Business Combination in order for the Business
    Combination to be approved.

Response:
In response to the Staff’s comments, the Company advises the Staff that pursuant to Article 49.4 of its Amended and Restated
Memorandum and Articles of Association, the Company may consummate the Business Combination so long as it is approved by ordinary resolution
and the Company has net tangible assets of at least US$5,000,001 immediately prior to, or upon such consummation of, or any greater net
tangible asset or cash requirement that may be contained in the agreement relating to, such Business Combination. An ordinary resolution
in this case, is a resolution passed by a simple majority of the Class A Ordinary Shares and Class B Ordinary Shares, voting as a single
class pursuant to Article 17.1 of the Amended and Restated Memorandum and Articles of Association. See pages 17, 34, 85, and 145
of Amendment No. 1.

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

May
11, 2023

Page
4

Q:
What interests do the current officers and directors have in the Business Combination?, page 16

    6.
    Please
    highlight the risk that the sponsor will benefit from the completion of a business combination and may be incentivized to complete
    an acquisition of a less favorable target company or on terms less favorable to shareholders rather than liquidate.

Response:
In response to the Staff’s comments, the Company has revised its disclosure on page 28 of Amendment No. 1 to highlight
the risk that the Sponsor will benefit from the completion of the business combination and, rather than liquidating, may be incentivized
to complete an acquisition of a less favorable target company or on terms less favorable to stockholders.

    7.
    Please
    highlight the material risks to public warrant holders, including those arising from differences between private and public warrants.
    Clarify whether recent common stock trading prices exceed the threshold that would allow the company to redeem public warrants. Clearly
    explain the steps, if any, the company will take to notify all shareholders, including beneficial owners, regarding when the warrants
    become eligible for redemption.

Response:
In response to the Staff’s comments to highlight the material risks to public warrant holders, including those created
from differences between private and public warrants, and to clarify whether recent stock trading prices exceed the threshold at which
the Company may redeem public warrants, the Company has added a disclosure on page 14 of Amendment No. 1 under the question, “How
do the public warrants differ from the Private Placement Warrants and what are the related risks for any public warrant holders post-Business
Combination?” Additionally, the Company has revised its disclosures on pages 34 and 52 of Amendment No. 1 by adding
the following risk factor: “Following the Business Combination, Jet.AI may redeem your unexpired Jet.AI Warrants prior to their
exercise at a time that is disadvantageous to you, thereby making your warrants worthless.”

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

May
11, 2023

Page
5

In
response to the Staff’s comments to explain the steps the Company will take to notify all shareholders, including beneficial owners,
regarding when the warrants become eligible for redemption, the Company has supplemented its disclosure on page 213 of Amendment
No. 1 as follows: “If and when the warrants become redeemable by us, we may not exercise our redemption right if the issuance of
shares of Jet.AI Common Stock upon exercise of the warrants is not exempt from registration or qualification under applicable state blue
sky laws or we are unable to effect such registration or qualification. Pursuant to the terms of the Warrant Agreement, if we elect to
redeem all of the redeemable warrants as described above, we will fix a date for the redemption (the “Redemption Date”) and
will mail the notice of redemption by first class mail, postage prepaid, not less than 30 days prior to the Redemption Date to the registered
holders of the warrants to be redeemed at their last addresses as they appear on our registration books. In addition, we will issue a
press release and file a current report on Form 8-K with the SEC containing notice of redemption. We are not contractually obligated
to notify investors when our warrants become eligible for redemption and do not intend to so notify investors upon eligibility of the
warrants for redemption, unless and until we elect to redeem such warrants pursuant to the terms of the Warrant Agreement.”

Disclosures
regarding the Company’s process for notifying shareholders when the warrants become eligible for redemption have also been added
to pages 14 and 52.

    8.
    Your
    charter waived the corporate opportunities doctrine. Please address this potential conflict of interest and whether it impacted your
    search for an acquisition target.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on pages 18, 28, 58, and 123
of Amendment No. 1 to address the potential conflict of interest resulting from the waiver of the corporate opportunities doctrine in
our charter. Further, the Company advises the Staff that it is not aware of any officer or director of the Company who refrained from
presenting any opportunity to acquire a target business to the Company in reliance on the charter’s limited waiver or the corporate
opportunities doctrine or as a result of a pre-existing fiduciary or contractual obligation. To the Company’s knowledge, the waiver
of the corporate opportunities doctrine in its charter did not impact its search for an acquisition target.

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

May
11, 2023

Page
6

    9.
    We
    note you disclose that your sponsor, officers and directors have agreed not to redeem any Class A Ordinary Shares held by them in
    connection with a shareholder vote to approve the Business Combination. Please describe any consideration provided in exchange for
    this agreement.

Response:
In response to the Staff’s comments, the Company confirms no consideration was provided in exchange for this agreement.
Further, the Company has revised its disclosures on pages 18, 28, 57, and 122 of Amendment No. 1 to state the same.

Q:
Do I have redemption rights?, page 18

    10.
    Please
    clarify whether public shareholders that redeem their shares will be able to retain their warrants. To the extent they will be able
    to retain their warrants, please quantify the value of the warrants, based on recent trading prices, that may be retained by redeeming
    stockholders assuming maximum redemptions and identify any material resulting risks.

Response:
In response to the Staff’s comments, the Company has revised its disclosure on page 19 of Amendment No. 1 to clarify
that the public warrants will be retained following the redemption of shares and the value and risks associated with the public warrants.

Summary
of the Proxy Statement/Prospectus

Conditions
To The Closing, page 24

    11.
    We
    note you disclose that the Business Combination Agreement is subject to the satisfaction or waiver of certain closing conditions.
    Please revise to clarify each condition that is subject to being waived, state which party may waive such condition and the consequences
    of any such waiver.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on pages 26-27 and 100-102 of Amendment
No. 1 to clarify which conditions are subject to being waived.

Risk
Factors

Jet
Token’s business and reputation rely on, and will continue to rely on, third parties, page 45

    12.
    We
    note you disclose that Jet Token has relied on a third-party app developer to develop the initial versions of its App and Jet Token
    expects to rely heavily on Cirrus to maintain and operate Jet Token’s leased aircraft for charter services. Please revise to
    clarify the nature of Jet Token’s relationship with such third parties, contractual or otherwise.

Response:
In response to the Staff’s comments, the Company has revised its disclosure on page 48 of Amendment No. 1. Jet Token
Inc., through its wholly owned subsidiary, Jet Token Management Inc., maintains contractual relationships with Cirrus Aviation for the
operational management, maintenance and chartering of each of Jet Token’s aircraft. Both Jet Token and Cirrus actively book charter
onto Jet Token aircraft. Cirrus books charter via its 24-hour charter department and Jet Token Inc. books charter via its App.

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

May
11, 2023

Page
7

Jet
Token no longer relies on a third-party app developer for its original Jet Token App because Jet Token’s strategy is to replace
its existing app with