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                                November 9, 2021

       William Horne
       Chief Executive Officer
       Ault Disruptive Technologies Corp
       11411 Southern Highlands Parkway, Suite 240
       Las Vegas, Nevada 89141

                                                        Re: Ault Disruptive
Technologies Corp
                                                            Registration
Statement on Form S-1
                                                            Filed November 5,
2021
                                                            File No. 377-05117

       Dear Mr. Horne:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comment. In our comment, we may ask you to provide us
with information so
       we may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to our comment, we may have additional comments.

       Registration Statement on Form S-1 filed November 5, 2021

       Our warrants are expected to be accounted for as equity . . . , page 69

   1.                                                   We note from your risk
factor disclosure on pages 33 and 69 that currently your warrants
                                                        are expected to be
accounted for as equity in your balance sheet, but you cannot guarantee
                                                        that your warrants
would not be classified as liabilities. We further note your disclosure
                                                        that if auditors of a
potential target disagree or the SEC issues a statement in the future, it
                                                        could result in
different accounting treatment and you may need to restate your financial
                                                        statements. These
statements appear to qualify the accounting treatment of the warrants.
                                                        Please tell us how this
disclosure is appropriate in light of the audit report that states the
                                                        financial statements
are the responsibility of management and in which your auditor
                                                        opines that the
financial statements present fairly, in all material respects, your financial
                                                        position and the
results of your operations and cash flows in conformity with accounting
 William Horne
Ault Disruptive Technologies Corp
November 9, 2021
Page 2
       principles generally accepted in the United States of America. Finally,
please tell us why
       the accounting for the warrants determines the terms and conditions of
the warrants.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Howard Efron at 202-551-3439 or Wilson Lee at
202-551-3468 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Patrick Costello at 202-551-8742 or Pam Long at 202-551-3765 with any
other
questions.



                                                            Sincerely,
FirstName LastNameWilliam Horne
                                                            Division of
Corporation Finance
Comapany NameAult Disruptive Technologies Corp
                                                            Office of Real
Estate & Construction
November 9, 2021 Page 2
cc:       Spencer G. Feldman, Esq.
FirstName LastName