7800 Shoal Creek Blvd.
Suite 230S
Austin, TX 78757
Austin, TX 78757
October 23, 2020
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re: Phunware, Inc.
Registration Statement on Form S-3
Originally Filed September 4, 2020
File No. 333-248618
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for the above-referenced Registration Statement be accelerated so that it will be declared effective at 9:30 a.m. Eastern Time on October 27, 2020, or as soon thereafter as is practicable.
Please contact Alex R. Allemann with Winstead PC at (512) 370-2800 once the Registration Statement is declared effective.
PHUNWARE, INC.
By: /s/ Alan S. Knitowski
Alan S. Knitowski
Chief Executive Officer
Alan S. Knitowski
Chief Executive Officer