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    Dykema
                                            Gossett PLLC

    111
    E. Kilbourn Ave.

    Suite
    1050

    Milwaukee,
    WI 53202

    www.dykema.com

    Tel:
    414-488-7300

    Hallie
                                            D. Heath

    Direct
    Dial: (414) 488-7337

    Email:
    HHeath@dykema.com

June
6, 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.

                                            Amendment No. 1 to Registration Statement on Form S-4

                                            Filed May 11, 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 May 26, 2023
(the “Comment Letter”), with respect to the Company’s Amendment No. 1 (“Amendment No. 1”)
to its registration statement on Form S-4 (the “Registration Statement”), filed with the SEC on May 11, 2023. The
Company is concurrently submitting a second amendment to the Registration Statement (“Amendment No. 2”), 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. 2.

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

    June
    6, 2023

    Page
    2

Amendment
No. 1 to Registration Statement on Form S-4

Questions
and Answers About the Business Combination

Q:
How do the public warrants differ from the Private Placement Warrants and what are the related risks for any public warrant holders...,
page 14

1. We
note your revised disclosure in response to prior comment 7. Please expand your discussion here and elsewhere to discuss that the Private
Placement Warrants are not redeemable and may be exercised on a “cashless basis,” whereas the public warrants are redeemable
and may only be exercised on a cashless basis if you call the public warrants for redemption and require any holder to exercise its public
warrants on a “cashless basis.” In this regard, we note your disclosure on page F-18.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on pages 14, 72, 213, 218 of Amendment No.
2.

Q:
Did the Oxbridge Board obtain a third-party valuation or fairness opinion in determining whether or not to proceed with the Business...,
page 16

2. We
note your response to prior comment 4 and reissue the comment in part. Please revise to provide a clear explanation as to why the Oxbridge
board determined to obtain a fairness opinion.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on page 16 of Amendment No. 2.

Summary
of the Proxy Statement/Prospectus, page 24

3. We
note your revised disclosure in response to prior comment 11 and reissue it in part. Please revise to clarify which party may waive each
condition that may be waived and the consequences of such wavier, including the condition that Jet.AI have cash on hand equal to or in
excess of $5,000,000 after distribution of all funds and payment of expenses.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on pages 26, 27 of Amendment No. 2.

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

    U.S.
                                            Securities and Exchange Commission

    Division
    of Corporate Finance

    June
    6, 2023

    Page
    3

Risk
Factors

Jet
Token’s business and reputation rely on, and will continue to rely on, third parties, page 48

4. We
note your revised disclosure in response to prior comment 12 states that Jet Token intends to continue to build its internal development
team and to gradually decrease on its reliance on external contractors for app development. We also note you state elsewhere that your
CharterGPT app is expected to be made available to the public in advance of or simultaneous with the closing of the proposed Business
Combination. Please revise to discuss the nature of work performed by external contractors, including whether such external contracts
develop any of your software, and file any agreements governing the relationship between Jet Token and such parties. In addition, please
discuss the current status of the CharterGPT app and the risks involved if there are delays or complications to Jet Token’s CharterGPT
app development.

Response: Jet
Token retains two individuals who act as external contractors. Both collaborate with Jet Token’s CTO, and Jet Token owns,
without restriction, all rights to all intellectual property generated for this project by the contractors. The nature of the work
performed by the external contractors relates to the design and implementation of the App’s front-end and back-end,
respectively. The front-end contractor envisions and renders a visually appealing and intuitive workflow for the App compatible with
the input requirements of the back-end. The App workflow includes but is not limited to registration, charter jet search, booking,
and payment. The back-end developer writes original computer code and integrates certain open-source software consistent with the
features described in Strategy-Artificial Intelligence. In response to the Staff’s comments, the Company has revised its
disclosures on pages 119, 175, 180 of Amendment No. 2.

Risks
Related to Oxbridge and the Business Combination

Our
Sponsor and certain of our directors and officers have interests in the Business Combination that are different from..., page 57

5. We
note your revised disclosure in response to prior comment 6. Please include corresponding disclosure here that the Sponsor 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 disclosures on page 56 of Amendment No. 2.

The
issuances of additional shares of Jet.AI Common Stock under the GEM Warrant may result in dilution of future Jet.AI stockholders...,
page 64

6. Please
revise this risk factor to include a cross-reference to your discussion of the Share Purchase Agreement on page 185.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on page 62 of Amendment No. 2.

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

    U.S.
                                            Securities and Exchange Commission

    Division
    of Corporate Finance

    June
    6, 2023

    Page
    4

Background
of the Business Combination

The
Oxbridge Board’s Reasons for the Approval of the Business Combination, page 111

7. We
note your revised disclosure in response to prior comment 19 reflects that Oxbridge’s board considered that Jet Token is poised
for expansion into new markets, including the Asian market. Please elaborate on the Jet Token’s plans, if any, to expand into the
Asian Market and address any risks related to such expansion.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on page 110 of Amendment No. 2.

8. Please
revise to provide a basis for your statement that the “Oxbridge Board believes the [private aviation] industry can expand to $80
billion by 2025.”

Response:
In response to the Staff’s comments, the Company has revised its disclosures on page 110 of Amendment No. 2.

Opinion
of Stanton Park Advisors, LLC, page 116

9. We
note you disclose that Stanton reviewed projections for the fiscal years ending December 31, 2023 to December 31, 2028 in arriving at
its opinion. However, your projections included on page 120 are for the fiscal years ending December 31, 2023 to December 31, 2027. Please
revise or advise.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on page 118 of Amendment No. 2 to include
the forecasted projections through to December 31, 2028.

10. Please
revise discuss in greater detail each of the material analyses conducted by Stanton Park Advisors, LLC as part of its opinion, and any
material assumptions underlying such analysis. Refer to Item 4(b) of Form S-4 and Item 1015(b)(6) of Regulation M-A. Provide support
for the ultimate conclusions reached in each of the comparable transactions and discounted cash flow analysis for determining the equity
value of Jet Token. In addition, please identify the nine comparable transactions and companies and provide quantitative disclosure for
the financial performance measures analyzed to support for the valuation multiples for the comparable transactions.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on page 115, 116 of Amendment No. 2.

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

    U.S.
                                            Securities and Exchange Commission

    Division
    of Corporate Finance

    June
    6, 2023

    Page
    5

The
Business Combination

Unaudited
Prospective Financial Information for Jet Token

Key
Financial Metrics, page 120

11. We
note your response to comment 21. In your revised disclosure, you expect the forecast for EBITDA Margin to rebound beginning in 2025
due to the expansion in higher margin revenues primarily related to CharterGPT’s ability to automate the charter process and lower
unit costs per charter booking. Please expand your disclosure to further explain your use of CharterGPT and the impact of this technology
on your business. In addition, please clarify why you have only identified the impact of CharterGPT in your change in forecasted EBITDA
Margins. In this regard, please tell us and expand your disclosure to state how you considered your other types of revenue and related
expenses in your projections, fully describing the material assumptions underlying your projections.

Response:
In response to the Staff’s comments, the Company has revised its disclosures on page 119 of Amendment No. 2.

Notwithstanding
the forecasted benefit of CharterGPT, we inadvertently omitted a more fulsome discussion of the source of margin improvement in the forecast
and have included it in Amendment No. 2. Subscription Revenue in the Software segment is the primary contributor to the growth in overall
forecasted EBITDA Margin because gross margins in Subscription Revenue are projected at a significantly higher level than the gross margins
associated with all other sources of revenue. EBITDA margins are projected to rise from a trough in 2024E of 8.6% to a peak of 18.6%
in 2028E. The increase in forecasted EBITDA margin is primarily attributable to Subscription Revenue (at an approximate 75% gross margin)
rising to 22.2% of sales in 2028E from 4.3% of sales in 2024E.

We
considered several factors such as the specific form of price, mix and volume that in each case could be multiplied together to generate
a revenue forecast and then attempted to forecast how one or more of those factors would be expected to change over time. With respect
to cost we looked at our fixed contractual obligations and historical experience to extrapolate our ongoing expense and how they might
vary. This granular approach to estimating revenue and cost, respectively, is expanded upon in Amendment No. 2.

Management’s
Discussion and Analysis of Financial Condition and Results of Operations of Jet Token, page 171

12. We
                                            note your revisions to your disclosure based on comment 23. Please address the following
                                            observations:

 ● In
                                            the revised disclosure you state, “In 2021, Jet Token booked $645,996 in revenue related
                                            to its App-generated charter bookings. During 2022 these revenues totaled $1.2 million, and
                                            $0.6 million an 89.5% increase from 2021.” Please revise as necessary.

Response: In
response to the Staff’s comments, the Company has revised its disclosures on page 172 of Amendment No. 2.

 ● In
                                            the revised disclosure you state, “…Jet Token also generates revenue through
                                            the direct chartering of its HondaJet aircraft by Cirrus. During 2022 this revenue amounted
                                            to approximately $1.0 million, an increase of $0.6 million, or 164.4% from the prior year.
                                            ...It cost $2.9 million to operate these aircraft in 2022, a $2.2 million, or 324.3%, increase
                                            over 2021, and resulted in a gross profit from operating the HondaJets of $0.4 million in
                                            2022 compared to a gross profit loss of $0.2 million in 2021.” Please further clarify
                                            how the $1 million revenue related to direct chartering of the HondaJet aircraft by Cirrus
                                            and the cost of $2.9 million to operate these aircraft resulted in a gross profit from operating
                                            the HondaJets of $0.4 million in 2022, rather than a loss of $1.9 million.

Response: In
response to the Staff’s comments, the Company has revised its disclosures on page 170 of Amendment No. 2.

 ● Please
                                            consider revising your discussion of results of operations to address each type of revenue
                                            and expense separately, rather than in the same paragraph.

Response: In
response to the Staff’s comments, the Company has revised its disclosures on page 170 of Amendment No. 2. Additionally, we note
that, though Cirrus may arrange for certain charters and receive commissions from Jet Token, that is the only element of Jet Token’s
costs that can be directly tied to the Cirrus charters. The cost of maintaining Jet Token’s fleet of aircraft, through Jet Token’s
agreement with Cirrus, is independent of the source of revenues from operating the aircraft. As a result, we believe it would be inappropriate
and potentially confusing to discuss the Cirrus charter revenues and just the commissions that are directly related to those charters
as it would not reflect the cost of maintaining and operating the aircraft that was chartered. Jet Token does not separately track and
allocate the contractual payments to Cirrus under its management agreement according to the nature of its relationship to the passenger(s)
booking that aircraft.

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

    U.S.
                                            Securities and Exchange Commission

    Division
    of Corporate Finance

    June
    6, 2023

    Page
    6

13. We
                                            note