SecProbe.io

CORRESP
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filename1.htm

Graubard Miller

The Chrysler Building

405 Lexington Avenue

New York,
N.Y. 10174-4499

(212) 818-8800

    Facsimile
    direct dial number

    (212) 818-8881
    (212) 818-8638

    email address

    jgallant@graubard.com

December
26, 2024

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Real Estate & Construction

100
F Street, NE

Washington,
D.C. 20549

  Re:
  LuxUrban Hotels Inc.

  Registration Statement on Form S-1

  Filed December 2, 2024

  File No. 333-283560

Ladies
and Gentlemen:

On
behalf of LuxUrban Hotels Inc. (the “Company”), we hereby respond as follows to the comment letter from the staff
of the Securities and Exchange Commission (the “SEC”) dated December 20, 2024, relating to the above-referenced Registration
Statement on Form S-1 (the “Registration Statement”). Captions and page references herein correspond to those set
forth in Amendment No. 1 to the Registration Statement filed on December 26, 2024.

Capitalized
terms used but not defined herein have the meanings ascribed to them on the Registration Statement.

Registration
Statement on Form S-1 filed December 2, 2024

Selling
Stockholders, page 15

 1. Please
                                            disclose in this section how each of the selling stockholders acquired the shares being offered
                                            for resale, as it appears that not all the private placements are described. For each entity,
                                            identify in the footnotes to the table the natural persons who have voting or dispositive
                                            power over the shares being offered. Clarify whether any of the selling stockholders have
                                            had within the past three years any position, office or other material relationship with
                                            the registrant or any of its predecessors or affiliates. See Item 507 of Regulation S-K.

Please
see the revised Selling Stockholders section and related table footnotes, as well as additional disclosures in the “Recent Developments”
section of the prospectus summary. We have indicated by footnote to each Selling Stockholder the transaction in which the indicated shares
were issued. The “Recent Developments” section describes each of the transactions – the 2024 Debt Placement, Greenle
issuances and shares-for-debt exchange. We have added addresses and the identify of each natural person having dispositive power of shares
held by entities. We have also identified any positions Selling Stockholders or their affiliates have had with the company.

Securities
and Exchange Commission

Page
2

December
26, 2024

Incorporation
of Information by Reference, page 20

 2. Please
                                            revise your incorporation by reference disclosure to include your Forms 10-Q for the quarters
                                            ended March 31, June 30, and September 30, 2024.

Please
note this section has been revised as directed above.

*************

If
you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.

    Sincerely,

    GRAUBARD
MILLER

    /s/ Brian L. Ross

  cc:
  Brian Ferdinand, Interim Chief Executive
  Officer