SecProbe.io

CORRESP
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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

July
7, 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. 3 to Registration Statement on Form S-4

    Filed
    June 22, 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 July 5, 2023
(the “Comment Letter”), with respect to the Company’s Amendment No. 3 (“Amendment No. 3”)
to its registration statement on Form S-4 (the “Registration Statement”), filed with the SEC on June 22, 2023.
The Company is concurrently submitting a fourth amendment to the Registration Statement (“Amendment No. 4”), 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. 4.

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

    July
    7, 2023

    Page
    2

Amendment
No. 3 to Registration Statement on Form S-4

Market,
Industry and Other Data, page 5

1. We
                                            note your statement regarding market data used in the prospectus cautioning investors “not
                                            to give undue weight” to estimates. This statement appears to imply a disclaimer of
                                            responsibility for this information in the registration statement. Please either revise this
                                            section to remove such implication or specifically state that you are liable for all information
                                            in the registration statement.

  Response:
                                            In response to the Staff’s comments, the Company has revised its disclosures on
                                            page 5 of Amendment No. 4.

The
Business Combination

Opinion
of Stanton Park Advisors, LLC, page 115

    2.
    We
    note your revised disclosure in response to prior comment 2. Please make corresponding revisions to your disclosures in this section.

    Response:
    In response to the Staff’s comments, the Company has revised its disclosures on page 116 of Amendment No. 4.

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

Liquidity
and Capital Resources, page 175

    3.
    We
                                            note your revision in response to comment 4. Net cash provided by financing activities in
                                            the table on page 175 is inconsistent with the amounts disclosed in the financial statements
                                            on page F-48. Please revise.

    Response:
    In response to the Staff’s comments, the Company has revised its disclosures on page 175 of Amendment No. 4.

General

    4.
    We
                                            note you disclose that this prospectus covers 7,918,408 shares of Jet.AI Common Stock (including
                                            Class A Ordinary Shares, Class B Ordinary Shares, Jet Token Common Stock and Jet Token Preferred
                                            Stock that will convert into shares of Jet.AI Common Stock in connection with the Business
                                            Combination, and shares issuable upon exercise or vesting of the Jet.AI Warrants, the Merger
                                            Consideration Warrants, the Jet.AI RSU Awards and the Jet.AI Options). However, it appears
                                            that such 7,918,408 shares does not include the shares to be issued in exchange for the Class
                                            A Ordinary Shares and Class B Ordinary Shares or shares issuable upon exercise or vesting
                                            of the Jet.AI Warrants and Merger Consideration Warrants. Please advise or revise.

    Response:
    In response to the Staff’s comments, the Company has revised the first page of the prospectus and elsewhere to reflect
    the total number of shares of Jet.AI Common Stock, public Jet.AI Warrants and Merger Consideration Warrants that may be issued in
    connection with the Business Combination and registered under this S-4.

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

    U.S.
                                            Securities and Exchange Commission

    Division
    of Corporate Finance

    July
    7, 2023

    Page
    3

    5.
    Please
    disclose that you have received a notice from Nasdaq indicating that the company is no longer in compliance with the minimum market
    value of listed securities set forth in Nasdaq Listing Rule 5550(b)(2) and include appropriate risk factor disclosure.

    Response:
    In response to the Staff’s comments, the Company has revised its disclosures on pages 63 and 189 of Amendment No. 4.

Thank
you for your review and consideration of the matters set forth in this Response and in Amendment No. 4. If you have any questions, please
contact the undersigned at (414) 488-7337 or hheath@dykema.com.

    Sincerely,

    Dykema
    Gossett PLLC

    /s/
Hallie
    D. Heath, Esq.

    Hallie
    D. Heath, Esq.

    cc:
    Jay
    Madhu

    Chief
    Executive Officer

    Oxbridge
    Acquisition Corp.

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