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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

    September 22, 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

    Katherine Bagley

Re: SportsMap Tech Acquisition Corp.

                                            Amendment No. 2 to Preliminary Proxy Statement on Schedule 14A

                                            Filed July 31, 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 August 14, 2023 (the “Comment Letter”) from the staff (the “Staff”)
of the Securities and Exchange Commission (“SEC” or the “Commission”), regarding the Company’s Amendment
No. 2 to Preliminary Proxy Statement on Schedule 14A, filed on July 31, 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.

Amendment No. 2  to Preliminary Proxy on Schedule
14A filed July 7, 2023

Summary of the Material Terms of the Transactions,
page 35

1. We note your response to comment 3, including your
amended disclosure related to the per share merger consideration. In addition to this disclosure, please amend your disclosure to
show the potential impact of redemptions on the per share value of the shares owned by non-redeeming shareholders at each redemption
level, taking into account not only the money in the trust account, but the post-transaction equity value of the combined company. Your
disclosure should show the impact of certain equity issuances on the per share value of the shares, including the exercises of public
and private warrants, options and the issuance of any earnout shares under each redemption scenario.

RESPONSE: We acknowledge the Staff’s comment and have
revised the disclosure on pages 8 and 9 accordingly.

 September 22, 2023

Page 2

The Background of SportsMap's Interaction with ICI,
page 113

2. We note your revised disclosure on page 117 in response
to prior comment 6 that the parties during the October 31, 2022 call "reviewed the status of pilot projects and other opportunities
in the pipeline" and that ICI's management believes that the active pipeline would "yield new revenue in 2023." Please
revise to expand your disclosure of the status of the pilot projects and other pipeline opportunities discussed on the October 31, 2022
call.

RESPONSE: We acknowledge the Staff’s comment and have
revised the disclosure on page 123 accordingly.

The Comparable Companies Approach, page 120

3. We note your response and revised disclosure in response
to prior comment 7, which we reissue in part. You disclose on page 120 that your preliminary comparable companies analysis conducted
in September 2022 was subsequently revised on December 15, 2022. Please revise to expand your discussion of the material differences
between the preliminary and subsequent comparable companies analyses.

RESPONSE:
We acknowledge the Staff’s comment and have revised the disclosure on pages 127 though 129 accordingly.

Certain Forecasted Financial Information for ICI,
page 126

4. We note your response to comment 10. Given the limited
historical revenue of ICI of only $7.3 million in 2022 and less than $1 million during the 3 months ended March 31, 2023, we continue
to believe additional clarity should be provided regarding the significant assumptions used and the basis for those assumptions in arriving
at the forecasted revenues for the 12 months ended June 30, 2024 of $22.1 million. In this regard, please address the following:

 · Your revised disclosures mention
                                            multiple amounts related to the Updated Forecast, including a probability-adjusted gross
                                            pipeline for realized enterprise SaaS revenues from identified customers and "in process"
                                            opportunities of approximately $4.2 million for the twelve-month period ending June 30, 2024,
                                            total forecast SaaS revenue of $3.4 million, probability adjusted gross pipeline for hardware
                                            sales of approximately $10.9 million, and a "go get" revenue target for hardware
                                            sales of approximately $5.8 million over the NTM Period. Please further clarify what each
                                            of these amounts represent as it is not clear based on their description as well as how these
                                            amounts correspond to the actual forecasted revenue amounts. Please clarify if there are
                                            actual customer commitments which serve as a basis for these assumptions; and

 · Your response to comment 15
                                            also addresses probability adjusted pipeline and the expectation of inventory to be sold
                                            in the twelve months subsequent to March 31, 2023. Please further clarify how this corresponds
                                            to the forecasted information provided.

RESPONSE: We acknowledge the Staff’s comment and have
revised the disclosure on pages 134 and 135 accordingly.

Information about ICI

Market Opportunity, page 170

5. We note your revised disclosure relating to the risks
specific to the Oil & Gas and Manufacturing markets in response to prior comment 12. Please revise to include balancing disclosure
to address the challenges and risks specific to the Distribution & Logistics and Utilities markets in this section as well.

RESPONSE: As discussed between members of the Staff and counsel
for ICI, the Company and ICI respectfully advise the Staff that they do not believe additional revisions to the Proxy Statement are needed
in order to address the Staff’s concern. Specifically, the Company and ICI note the following disclosure beginning on page 182,
which the Company and ICI previously added in response to prior comment 12 and describes risks relating to all of ICI’s markets,
including the Distribution & Logistics and Utilities markets:

“While ICI has a long history of selling, implementing and
supporting device-only thermal systems into each of the four target markets, there are some risks inherent to selling integrated device
and software sensing solutions into each of these target markets. Please see the following risk factors in “Risk Factors”
for a more detailed discussion relating to the risks that apply to each of our four target markets, particularly as they relate to the
adoption of ICI’s hardware and software offerings in each of the four target markets:

 September 22, 2023

Page 3

 · If
                                            ICI’s products are not adopted in its targeted end markets, its business will be materially
                                            and adversely affected.

 · ICI
                                            may not be able to anticipate changing customer and consumer preferences or respond quickly
                                            enough to changes in technology and standards to be able to develop and introduce commercially
                                            viable products.

 · Product
                                            integration could face complications or unpredictable difficulties, which may adversely impact
                                            customer adoption of ICI’s products and its financial performance.

 · The
                                            markets in which ICI competes are characterized by technological change, which requires ICI
                                            to continue to develop new products and product innovations and could adversely affect market
                                            adoption of its products.

 · Since
                                            many of the markets in which ICI competes are new and rapidly evolving, it is difficult to
                                            forecast long-term end-customer adoption rates and demand for its products.

 · ICI’s
                                            estimate of total addressable market is subject to numerous uncertainties. If ICI has overestimated
                                            the size of its total addressable market now or in the future, its future growth rate may
                                            be limited.”

Results of Operations, page 183

6. We note your response to comment 14. Please also separately
quantify the extent to which changes in revenues for the year ended December 31, 2022 are attributable to changes in prices, changes
in volume, or to the introduction of new products or services pursuant to Item 303(b)(2)(iii) of Regulation S-K. Please reconcile your
statement on page 185 that "The Company did not introduce new products or software subscription services for the three months ended
March 31, 2023" with the disclosure on page 21 which states that it launched its SmartIR cloud-software product suite in the first
quarter of 2023. Also, disclose whether sales returns have been material and if so quantify the impact on reported sales. Further, please
expand your disclosure to explain the material changes in gross margin for each period presented.

RESPONSE: We acknowledge the Staff’s comment and have revised
the disclosure on pages 196 through 198 accordingly.

Critical Accounting Policies and Estimates, page 190

7. Your response to prior comment 15 does not clearly indicate
how you reasonably concluded that no material inventory allowance was required at March 31, 2023. Since inventory is ICI's largest asset,
please include a disclosure within the critical accounting policies section that clearly identifies any known factors that materially
impact inventory measurement risk. For example, specifically disclose whether you have performed a physical count of inventory since
the October 2022 flood. Clarify whether any such physical inventory count covered all units of inventory or just a portion thereof. Given
ICI's internal control weaknesses (page 192), please tell us whether there were any material disparities between ICI's inventory counts
and its corresponding inventory/financial accounting records during the periods presented. If so, then that risk element should also
be disclosed so that readers can understand how the material weakness can impact your inventory accounting. See Item 303(b)(3) of Regulation
S-K.

RESPONSE: We acknowledge the Staff’s comment in relation to the
description of factors that impact the measurement risk of inventories and have revised the disclosure related to Critical Accounting
Policies and Estimates on pages 203 and 204 accordingly.

 September 22, 2023

Page 4

As discussed in the July 28, 2023 response to the Staff’s previous
comment 15, prior to March 31, 2023, ICI completed a detailed review of its inventories and determined that no impairment was required
based on its updated business plan, quarterly inventory count, inventory profit margin analysis and comparing cost with net realizable
value at that time.

The Company evaluates at the end of each quarter and year-end its inventory
reserve based on the following:

(i) its current business plan to estimate the demand of inventories
based on market environment, current portfolio of customers and upcoming purchase orders from customers,

(ii) full count of inventory at year end and 80% coverage count on
a quarterly basis to identify if there are any inventories that are not sold in the operating business cycle, have slow movement or
are obsolete, and

(iii) assessing if the costs of inventories are greater than net realizable
value and should be impaired.

On October 8, 2022, the Company incurred a casualty loss. ICI performed
a physical inventory count of all inventory on January 19, 2023 accounting for a casualty loss of $1,376,000 related to a flood in the Beaumont
warehouse. ICI did not identify material count discrepancies between its inventory count and its corresponding inventory/financial accounting
records and did not identify any material weakness in controls for inventories as of December 31, 2022.The company completed its quarterly
cycle count procedures in 2023, which did not result in any significant adjustments to recorded inventory balances. This amount is offset
by insurance recoveries of $1,221,000, resulting in a net $155,000 of casualty losses.

As of June 30, 2023, ICI updated its 2023 business plan based on
the most up-to-date market information, performing a detailed analysis relating to all inventory, historical turnover of inventory,
upcoming future orders from customers, technical specifications of devices actually deployed in the emerging highest-demand
industrial applications, comparison of cost with net realizable value and prospective gross profit margin. On the basis of this
analysis, ICI concluded that an inventory reserve of $1,386,000 should be recorded for the six months ended June 30, 2023, which has
been reflected in the unaudited financial statements included in Amendment No. 3 to the Proxy Statement. The inventory reserve
recorded is mainly related to temperature reference products and specific dual-medium high-resolution cameras (FM 640+ P) that are
better suited to biorisk applications and cannot be easily adapted to industrial applications. This inventory is not expected to be
sold within the next twelve months, based on customer demand and current market conditions as assessed by ICI during its close
process for the three months ended June 30, 2023. As part of this analysis, the Company reassessed if this inventory reserve should
be recognized in prior periods, December 31, 2022 or March 31, 2023, concluding that based on an analysis of slow moving
inventories, the business plan and potential customer purchases orders at such dates, no inventory allowance should be
recognized.

Management revisited the assumptions relating to these specific items
and observed three significant changes (one external, one a blend of external and internal, and one internal) that led to the decision
to create an inventory reserve as of June 30, 2023:

 1. External – the expected ongoing demand for biorisk applications
was lower than had been expected. As part of its operating plan update in June 2023, the Company changed its strategy on certain biorisk
applications. The Company reduced the value of its inventory for estimated obsolescence or lack of marketability by the difference between
the cost of the affected inventory and the NRV. No inventory reserve was recognized for the three months ended March 31, 2023 and for
the year ended December 31, 2022 on the basis of expected ongoing biorisk sales and expected ability to repurpose for industrial applications.
Starting in June 2023, the Company has focused its commercial efforts on four industry verticals: warehouse and logistics (conveyor systems);
manufacturing; utilities; and oil & gas.

 2. External and internal – the market demand for industrial applications such as Food & Beverage that could have reasonably
required FM 640+ P cameras and ICITRS101 Temperature Reference Sources (i.e., requiring tight temperature thresholds, visible camera feeds,
need for static temperature reference) was less developed than expected or the Company’s commercial capabilities had not yet
been sufficiently develop