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:			Acceleration Request of Smith Micro Software, Inc.
			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