May 13, 2026

Victor Huang
Chief Executive Officer
Airship AI Holdings, Inc.
8210 154th Ave NE
Redmond, WA 98052

        Re: Airship AI Holdings, Inc.
            Registration Statement on Form S-3
            Filed May 11, 2026
            File No. 333-295755
Dear Victor Huang:
       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 Jan Woo at 202-551-3453 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:    David J. Levine