United States securities and exchange commission logo September 13, 2022 Jennifer Reinke General Counsel Smith Micro Software, Inc. 5800 Corporate Drive Pittsburgh, PA 15237 Re: Smith Micro Software, Inc. Registration Statement on Form S-3 Filed September 2, 2022 File No. 333-267255 Dear Ms. Reinke: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 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 Priscilla Dao, Staff Attorney, at (202) 551-5997 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Jennifer Minter