October 18, 2024

Robert Arigo
Chief Executive Officer
LuxUrban Hotels Inc.
2125 Biscayne Blvd, Suite 253
Miami, Florida 33137

       Re: LuxUrban Hotels Inc.
           Registration Statement on Form S-1
           Filed October 8, 2024
           File No. 333-282551
Dear Robert Arigo:

       We have conducted a limited review of your registration statement and
have the
following comments.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-1
General

1.     We note your disclosure on page 4 that as of the date of this
prospectus, you have
       issued or are required to issue to Greenle under the May 2024 waiver
modification an
       aggregate of 20,828,324 additional shares of common stock. Please
clarify the status
       of any shares you are required to issue to Greenle and have not yet
issued and why
       these shares have not yet been issued. To the extent the issuance of
such shares are
       subject to conditions please provide your analysis of why the offering
of such shares
       should not be characterized as a primary offering. For guidance see
Compliance and
       Disclosure Interpretations Securities Act Sections Question 139.11.
 October 18, 2024
Page 2
Risk Factors, page 8

2.     We note your disclosure that you will have a hearing with Nasdaq on or
about
       October 15, 2024. Please update your disclosure to reflect the results
of such hearing
       as applicable.

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Ruairi Regan at 202-551-3269 or Pam Howell at
202-551-3357 with
any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate & Construction
cc:   Brian L. Ross, Esq.