United States securities and exchange commission logo May 12, 2020 Timothy C. Huffmyer Chief Financial Officer Smith Micro Software, Inc. 120 Vantis, Suite 350 Aliso Viejo, CA 92656 Re: Smith Micro Software, Inc. Registration Statement on Form S-3 Filed May 7, 2020 File No. 333-238053 Dear Mr. Huffmyer: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rule 461 regarding requests for acceleration. 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. Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or, in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Brian Novosel, Esq.