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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 26, 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. 5 to Registration Statement on Form
    S-4

    Filed July 18, 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 26,
2023 (the “Comment Letter”), with respect to the Company’s Amendment No. 5 (“Amendment No. 5”)
to its registration statement on Form S-4 (the “Registration Statement”), filed with the SEC on July 18, 2023. The
Company is concurrently submitting a sixth amendment to the Registration Statement (“Amendment No. 6”), 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. 6.

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 26, 2023

Page 2

Amendment
No. 5 to Registration Statement on Form S-4

General

1. We
                                            note your reference to the 2023 Extension Meeting and 2023 Extension Amendment Proposal.
                                            We further note you are also asking Oxbridge stockholders to vote at the 2023 Extension Meeting
                                            to adopt amendments to the Existing Organizational Documents that would allow Oxbridge to
                                            consummate the business combination even if Oxbridge will have less than $5,000,001 in net
                                            tangible assets (the “Redemption Limitation Amendment Proposal”). Please include
                                            a Question and Answer on the 2023 Extension Amendment Proposal and the Redemption Limitation
                                            Amendment Proposal. Explain why you are asking stockholders to vote on this proposal now,
                                            as opposed to at an earlier time. Additionally, provide a discussion of the related risks
                                            for investors and the post-business combination company and include corresponding disclosure
                                            in the risk factors section. Lastly, identify the provisions that Oxbridge is relying on
                                            in determining that the ordinary shares are not at risk of being deemed a penny stock under
                                            Exchange Act Rule 3a51-1, and discuss the impact that the trust falling below $5,000,001
                                            would have Oxbridge’s exchange listing and the consideration given to this possibility
                                            in your determination that this provision is no longer needed to avoid the definition of
                                            penny stock. In that regard, we note you disclose that you 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).

Response:
In response the Staff’s comments, the Company respectfully advises the Staff that it has filed an Amended Proxy Statement,
on July 26, 2023, removing the “Redemption Limitation Amendment Proposal” in its entirety. Additionally, the Company has
revised its disclosures on page 19 of Amendment No. 6 to include a Question and Answer on the 2023 Extension Amendment Proposal.

2. We
                                            note that the Business Combination Agreement is subject to the satisfaction or waiver of
                                            certain closing conditions, including that Oxbridge shall have at least $5,000,001 of net
                                            tangible assets following the exercise of Redemption Rights. Please revise to clarify whether
                                            the parties have waived this condition to the closing.

Response:
In response the Staff’s comments, the Company respectfully advises the Staff that the parties have not waived the closing
condition that the Company have at least $5,000,001 of net tangible assets following the exercise of the Redemption Rights. As noted
in the registration statement, it is not a waivable condition.

U.S. Securities and Exchange Commission

Division of Corporate Finance

July 26, 2023

Page 3

3. Please
                                            revise your sensitivity analysis to show the impact on the maximum redemption scenario assuming
                                            approval of the Redemption Limitation Amendment Proposal.

Response:
In response the Staff’s comments, the Company respectfully advises the Staff that the Company has filed an Amended Proxy
Statement, on July 26, 2023, removing the “Redemption Limitation Amendment Proposal” in its entirety. As such, the Company
determined revisions to the sensitivity analysis for the maximum redemption scenario were no longer necessary.

*
        *         *

Thank
you for your review and consideration of the matters set forth in this Response and in Amendment No. 6. 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

    Hallie D. Heath, Esq.

    cc:
    Jay Madhu

    Chief Executive Officer

    Oxbridge Acquisition Corp.