SecProbe.io

CORRESP
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    NELSON
                                            MULLINS RILEY &

    SCARBOROUGH
    LLP

    ATTORNEYS
    AND COUNSELORS AT LAW

    Andrew
                                            M. Tucker

                                            T: 202.689.2987

    Andy.Tucker@nelsonmullins.com

    101
                                            Constitution Avenue, NW

    Suite
    900

    Washington
    D.C., 20001

    T:
    202.689.2800 F: 202.689.2860

    nelsonmullins.com

November
22, 2023

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    Attention:
    Jenifer
    Gallagher

Karl
Hiller

Anuja
A. Majmudar

Timothy
S. Levenberg

    RE:
    Amphitrite
    Digital Incorporated

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

Submitted
November 22, 2023

File
No. 333-275379

Ladies
and Gentlemen:

On
behalf of Amphitrite Digital Incorporated (the “Company”), we are hereby responding to the letter dated November
20, 2023 (the “Comment Letter”) from the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”), regarding the Company’s Registration Statement on Form S-1
filed on November 7, 2023 (the “Registration Statement”). In response to the Comment Letter and to update certain
information in the Registration Statement, the Company is publicly filing its Amendment No. 1 to the Registration Statement on Form S-1
(the “Amended Registration Statement”) with the Commission today. The numbered paragraphs below correspond
to the numbered comments in the Comment Letter, and the Staff’s comments are presented in bold.

Registration
Statement on Form S-1 filed November 7, 2023

Unaudited
Pro Forma Consolidated Financial Information, page 62

 1. We
                                            understand that your pro forma balance sheet is intended to give effect to the proposed acquisition
                                            of Paradise Group of Companies (PGC) and the offering, as if these events occurred on September
                                            30, 2023, although you also include an adjustment indicating you intend to repay a note payable
                                            that arose in connection with your acquisition of Paradise Adventures, LLC, (PA) earlier
                                            in the year, as referenced in Note A on page 70. However, unless the counterparty is intending
                                            to return cash that had been paid as interest on the loan, we do not see support for the
                                            related adjustments described in Note B on page 70 and Note L on page 71, to remove interest
                                            expense previously recorded and to restore the associated cash expenditure. Please revise
                                            your pro forma balance sheet accordingly.

Response:
The Company acknowledges the Staff’s comment and respectfully advises the Staff that it has removed adjustments related to repayment
of the note payable that arose in connection with the acquisition of Paradise Adventures LLC. The Company has revised the Amended Registration
Statement on pages 18, 58, 70, and 71 accordingly.

 2. We
                                            note that in response to prior comment 5 you present details of management’s adjustments
                                            depicting the synergies you believe you will realize upon completion of the acquisitions
                                            of PA and PGC. Please revise your tables on pages 73 and 75 to present accurate summations
                                            of management’s adjustments.

Please
also revise your reconciliations as necessary to begin with the pro forma net loss amounts that are presented in your pro forma statements
of operations. For example, the pro form net loss amounts for the nine months ended September 30, 2023 do not presently agree.

Response:
The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company has revised its disclosures on
pages 73 and 75 of the Amended Registration Statement to present accurate summations of management adjustments. The Company further acknowledges
the Staff’s comment on reconciliation of pro forma net loss amounts and has revised its disclosures accordingly.

 3. On
                                            the pro forma statement of operations for the nine months ended September 30, 2023 you include
                                            an adjustment to decrease interest expense by $1,553,065; however, this amount does not agree
                                            to details included in the note for pro forma adjustment M.

Please
revise pro forma adjustment M or the associated disclosures as necessary to resolve this inconsistency.

Response:
The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company has revised its disclosure in
Note I in the Amended Registration Statement to provide the pro forma decrease of interest expense to resolve the inconsistency.

*     *     *     *     *

If
you have any additional questions regarding any of our responses or the Amended Registration Statement, please do not hesitate to contact
Andrew Tucker at (202) 689-2987.

    Very
    truly yours,

    /s/
    Andrew M. Tucker

    Andrew
    M. Tucker

    cc:
    Scott
                                            Stawski, Executive Chairman, Amphitrite Digital, Inc.

    Rob
    Chapple, Chief Executive Officer, Amphitrite Digital, Inc.