July 20, 2026
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: Jan Woo
Re: | Acceleration Request of Smith Micro Software, Inc. |
| Registration Statement on Form S-1 |
| Filed July 10, 2026 |
| File No. 333-297376 |
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| Request for Acceleration of Effectiveness |
Dear Ms. Woo:
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. 333-297376), so that it may become effective on Wednesday, July 22, 2026, 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, |
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| Smith Micro Software, Inc. |
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| By: | /s/ Timothy C. Huffmyer |
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| Timothy C. Huffmyer |
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| President and Chief Executive Officer |
cc: | William W. Smith, Jr., Executive Chairman of the Board |