SMITH MICRO SOFTWARE, INC. — Regulatory Filings 2024

Jul 8, 2024

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July 8, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance, Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

Attention: Uwem Bassey; Matt Derby

Re:
Registration Statement on Form S-1
Filed June 27, 2024
File No. 333-280542
Request for Acceleration of Effectiveness

Dear Messrs. Bassey and Derby:

Pursuant to Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, Smith Micro Software, Inc. (the “Company”) hereby respectfully requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-280542), so that it may become effective on July 10, 2024, at 5:00 p.m., Eastern Time, or as soon thereafter as practicable. The Company hereby authorizes Brian Novosel, Esq., and Jennifer Minter, Esq. of Buchanan Ingersoll & Rooney PC, counsel to the Company, to orally modify or withdraw this request for acceleration.

Please contact Brian Novosel of Buchanan Ingersoll & Rooney PC, counsel to the Company, at (412) 562-5266, or in his absence, Jennifer Minter at (412) 562-8444, to provide notice of effectiveness, or if you have any other questions or concerns regarding this matter.

Sincerely,
Smith Micro Software, Inc.
By:	/s/ James M. Kempton
	James M. Kempton
	Vice President, Chief Financial Officer and Treasurer

cc: William W. Smith, Jr., Chairman of the Board, President and Chief Executive Officer