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

    Kate
                                            Bechen

    Direct
    Dial: (414) 488-7333

    Email:
    KBechen@dykema.com

    October
    10, 2024

    U.S.
                                            Securities and Exchange Commission

    Division
    of Corporate Finance

    Office
    of Energy & Transportation

    100
    F Street, N.E.

    Washington,
    D.C. 20549

    Attention:
    Cheryl Brown and Liz Packebusch

    Re:
    Jet.AI
    Inc.

    Amendment
    No. 3 to Registration Statement on Form S-1

    Filed
    September 26, 2024

    File
    No. 333-279385

Dear
Ms. Brown and Ms. Packebusch:

This
response letter (this “Response”) is submitted on behalf of Jet.AI Inc. (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. Winston, dated October 9, 2024 (the
“Comment Letter”), with respect to the Company’s Amendment No. 3 (“Amendment No. 3”) to its
Registration Statement on Form S-1 (the “Registration Statement”), filed with the SEC on September 26, 2024. 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

October
10, 2024

Page
2

Amendment
No. 3 to Registration Statement on Form S-1 filed September 26, 2024

The
Selling Stockholder Transaction, page 5

    1.
    We
    note your response to prior comment one and your disclosure here that each share of Series B Preferred Stock converts into a number
    of shares of your Common Stock, subject to certain limitations, including a beneficial ownership limitation of 4.99% (calculated
    in accordance with the rules promulgated under Section 13(d) of the Securities Exchange Act of 1934, as amended (“Exchange
    Act”)), which can be adjusted to a beneficial ownership limitation of 9.99% upon 61 days prior written notice by the Selling
    Stockholder. Please revise your disclosure to clearly state, if true, that the beneficial ownership limitation does not prevent the
    Selling Stockholder from selling some of its holdings and then receiving additional shares; and that, in this way, the Selling Stockholder
    could sell more than the beneficial ownership limitation while never holding more than this limit.

Response:
In response the Staff’s comments, the Company has revised its disclosures on pages 5, 35, 46 and 100 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) 488-7333 or KBechen@dykema.com.

    Sincerely,

    Dykema
    Gossett PLLC

    /s/
    Kate Bechen

    Kate
    Bechen, Esq.

    cc:
    Mike
    Winston

    Interim
    Chief Executive Officer

    Jet.AI
    Inc.