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    ArentFox Schiff
    LLP

    1717 K Street NW

    Washington, DC 20006

    202.857.6000        main

    202.857.6395        fax

    afslaw.com

    Ralph De Martino

    Partner

    (202)
    724-6848     direct

    ralph.demartino@afslaw.com

July 7, 2023

Division
of Corporation Finance
 Office of Industrial Applications and Services

United States Securities and Exchange Commission

100 F St NE

Washington, DC 20549

    Attention:
    Jane Park

    Jordan Nimitz

Re: SportsMap Tech Acquisition
Corp.

Preliminary Proxy Statement on Schedule 14A

Filed May 10, 2023

File No. 001-40916

To Whom It May Concern:

The undersigned serves as counsel to SportsMap Tech
Acquisition Corporation (“SportsMap” or the “Company”). On
behalf SportsMap, we are hereby responding to the letter dated June 6, 2023 (the “Comment Letter”) from the staff
(the “Staff”) of the Securities and Exchange Commission (“SEC” or the “Commission”),
regarding the Company’s Preliminary Proxy Statement, on Schedule 14A filed on May 10, 2023 (the “Proxy
Statement”). For the convenience of the Staff, the comments included in the Comment Letter are posted below (in bold)
and SportsMap’s response follows each comment.

Preliminary Proxy on Schedule 14A filed May 10, 2023

Cautionary Note Regarding Forward-Looking Statements, page 5

1. We
                                            note your statements on this page that investors “should not place undue reliance”
                                            on the forward-looking statements in deciding how to vote their shares of SportsMap Common
                                            Stock on the proposals set forth in the proxy statement. We also refer to your statements
                                            on pages 115 and 116 cautioning investors not to place undue reliance on prospective
                                            financial information included in the prospectus. Please revise these statements to remove
                                            any implication that investors are not entitled to rely on disclosure in your registration
                                            statement.

RESPONSE: We acknowledge the Staff’s comment and have
revised the disclosure on pages 5, and 125 to 127 accordingly.

    July
    7, 2023

    Page
    2

Questions and Answers about the Business Combination, page 7

2. We note
                                            your disclosure that SportsMap stockholders elected to redeem 9,865,056 public shares of
                                            SportsMap common stock in connection with the special meeting of SportsMap stockholders held
                                            on April 14, 2023. Please amend your disclosure in the summary term sheet, risk factors,
                                            and where appropriate throughout your filing, to disclose the percentage of stockholder redemptions
                                            relative to total shares outstanding as of the date of your filing.

RESPONSE: We acknowledge the Staff’s comment and have
revised the disclosure on pages 9, 26, 27, 35, 84, 96, 108, 111, 162 and 201 accordingly.

Q: How will the level of redemptions by SportsMap Stockholders
affect the ownership of non-redeeming SportsMap Stockholders in New ICI . . ., page 8

3. We note
                                            that the post-business combination ownership level of your SportsMap Advisors appears to
                                            reflecting the $4,025,000 fee payable to Roth Capital. Please revise your table to include
                                            also the M&A Advisory Fees payable to Roth Capital and Craig Hallum. Please also revise
                                            your disclosure to disclose the effective fees on a percentage basis for shares at each redemption
                                            level presented in your sensitivity analysis related to dilution.

RESPONSE: We acknowledge the Staff’s comment and have
revised the disclosure on pages 9, 25, 27, 96, 108, and 201 accordingly.

Q: Did the SportsMap Board obtain a third-party valuation or
fairness opinion in determining whether or not to proceed . . ., page 13

4. We note
                                            that it does not appear that SportsMap Board sought a third-party valuation and did not receive
                                            any valuation report or opinion from a third party in connection with the business combination.
                                            Please disclose any discussions related to obtaining a fairness opinion for the business
                                            combination and the basis for the SportsMap Board determining it was not necessary to obtain
                                            a fairness opinion for the business combination.

RESPONSE: We acknowledge the Staff’s comment and have
revised the disclosure on pages 14, 72 and 119 accordingly.

Summary of the Proxy Statement, page 19

5. Please
                                            revise to expand your descriptions of ICI in this section. Please expand your disclosure
                                            to discuss the types of products and services ICI provides and how it generates revenue.
                                            Please also balance your disclosure to include equally prominent disclosure of the limitations
                                            and challenges you face in implementing your business strategy, including but not limited
                                            to, your net income (loss) for the year ended December 31, 2022 and your limited operating
                                            history and substantial dependence on a limited number of customers. Please also disclose
                                            that the audit opinion for SportsMap includes a paragraph related to substantial doubt about
                                            the ability of SportsMap to continue as a going concern.

RESPONSE:
We acknowledge the Staff’s comment and have revised the disclosure on pages 20 and 21 accordingly.

    July
    7, 2023

    Page
    3

Organizational Structure, page 25

6. Please
                                            amend your disclosure to provide a diagram of the post-business combination ownership structure
                                            of New ICI, including ownership percentages of the relevant parties.

RESPONSE:
We acknowledge the Staff’s comment and have revised the disclosure on page 29 accordingly.

Summary of the Material Terms of the Transactions, page 32

7. We note
                                            your disclosure on page 20 that the Adjusted Equity Value “will be equal to (a) $100,000,000,
                                            less (b) the aggregate amount of ICI’s outstanding indebtedness, plus (c) the
                                            aggregate exercise price that would be paid in respect of participating options to acquire
                                            shares of ICI Common Stock if all such options were exercised in full immediately prior to
                                            the Effective Time, plus (d) all cash and cash equivalents of ICI, plus (e) the
                                            aggregate principal amount of any ICI Convertible Notes entered into by ICI...” You
                                            also disclose on page 32 that the “aggregate merger consideration payable to holders
                                            of ICI common stock and options will be…equal to the Adjusted Equity Value, together
                                            with any Earnout Shares…” Please amend your Summary of the Material Terms to
                                            provide an estimated Adjusted Equity Value and per share merger consideration as of a recently
                                            practicable date.

RESPONSE:
We acknowledge the Staff’s comment and undertake to provide an estimate of the Adjusted Equity Value prior to finalizing and mailing
of the Proxy Statement. We have revised the disclosure on page 22 accordingly. As the total merger consideration paid to ICI Shareholders
is not adjusted for the number of shares of ICI Common Stock outstanding at the Closing, we respectfully advise the Staff that we do
not believe that the per share merger consideration is material or helpful to holders of SportsMap Common Stock.

Risks Related to SportsMap and the Business Combination, page 66

8. Please
                                            highlight the material risks to public warrant holders, including those arising from differences
                                            between private and public warrants. We note that page 3 states that the Public Warrants
                                            are redeemable following the initial business combination. Please discuss the circumstances
                                            in which the public warrants are eligible to be redeemed by the Company. To the extent that
                                            there is a threshold trading price of common stock that would allow the company to redeem
                                            the warrants, please clarify whether recent common stock trading prices exceed that threshold.
                                            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: We acknowledge the Staff’s comment and have
revised the disclosure on pages 76 and 77 accordingly.

Activities taken by SportsMap Stockholders to increase the likelihood
of approval..., page 71

9. We note
                                            disclosure here that at any time prior to the special meeting, the Sponsor, SportsMap’s
                                            officers, directors and advisors and/or their respective affiliates may purchase shares from
                                            institutional and other investors who vote, or indicate an intention to vote, against the
                                            business combination proposal, or execute agreements to purchase shares from such investors
                                            in the future, or they may enter into transactions with such investors and others to provide
                                            them with incentives to acquire shares of SportsMap common stock. You further state that
                                            the purpose of the share purchases could be to vote in favor of the business combination.
                                            Please provide your analysis on how such purchases comply with Rule 14e-5. To the extent
                                            that you are relying on Tender Offer Compliance and Disclosure Interpretation 166.01 (March 22,
                                            2022), available on our public website, please provide an analysis regarding how it applies
                                            to your circumstances. Revise your disclosure as appropriate for consistency.

RESPONSE: We acknowledge the Staff’s comment and
confirm that any such purchase of SportsMap shares will comply with the conditions indicated in Tender Offer Compliance and
Disclosure Interpretation Question 166.01 (“C&DI Question 166.01”). In response to the Staff’s
comments, we have also revised the disclosure on pages 70, 71, 148 and 149 accordingly to clarify that any public shares purchased
by the Sponsor or affiliates of SportsMap will be structured in compliance with the requirements of Rule 14e-5 under the Exchange
Act. We also respectfully inform the Staff that, to the extent the Company makes any such purchases, the Company intends to file in
a Current Report on Form 8-K the requisite information outlined in C&DI Question 166.01. With respect to the statement that the
purpose of such share purchases could be to vote in favor of the business combination, we respectfully inform the Staff that we have
removed such statement from page 75.

    July
    7, 2023

    Page
    4

Following the Business Combination, warrants will become exercisable
for New ICI Common Stock, which would increase the number . . ., page 73

10. Quantify
                                            the value of warrants, based on recent trading prices, that may be retained by redeeming
                                            stockholders assuming maximum redemptions and identify any material resulting risks.

RESPONSE: We acknowledge the Staff’s comment and have
revised the disclosure on pages 76 and 77 accordingly.

Ownership of New ICI, page 101

11. Please
                                            revise to disclose all possible sources and extent of dilution that shareholders who elect
                                            not to redeem their shares may experience in connection with the business combination. Provide
                                            disclosure of the impact of each significant source of dilution, including warrants retained
                                            by redeeming shareholders and the two tranches of Earnout Shares, at each of the redemption
                                            levels detailed in your sensitivity analysis, including any needed assumptions.

RESPONSE:
We acknowledge the Staff’s comment and have revised the disclosure on pages 9, 10, 27, 96, 97, 108 and 201
to 202 accordingly.

The Background of SportsMap’s Interaction with ICI, page 106

12. Please
                                            describe how ICI was identified as a potential target and by whom, and how the negotiations
                                            were started and by whom.

RESPONSE:
We acknowledge the Staff’s comment and have revised the disclosure on page 113 accordingly.

13. We note
                                            that the parties discussed the process of raising capital in a PIPE financing on a call on
                                            September 12, 2022. Please clarify the current status of discussions and negotiations
                                            regarding a PIPE transaction. To the extent that negotiation and marketing processes for
                                            a PIPE are ongoing, please disclose material details of those processes, including who selected
                                            the potential PIPE investors, what relationships the PIPE investors have to SportsMap, the
                                            Sponsor, ICI and its affiliates, and advisors, if any, and how the terms of the PIPE
                                            transaction were determined.

RESPONSE:
We acknowledge the Staff’s comment and have revised the disclosure on page 110 accordingly.

    July
    7, 2023

    Page
    5

14. Please
                                            revise your background section to provide more detail regarding the topics discussed in the
                                            due diligence calls related to ICI’s financials and competitive opportunity. We note
                                            that SportsMap considered these calls to be constructive in enabling its understanding of
                                            ICI’s value proposition and growth prospects, and the factors that considered to arrive
                                            at the $100 million valuation. Please revise your disclosure to discuss wha