April 11, 2019

Barrett Garrison
Chief Financial Officer
Digital Turbine, Inc.
111 Nueces Street
Austin, TX 78701

       Re: Digital Turbine, Inc.
           Registration Statement on Form S-3
           Filed April 9, 2019
           File No. 333-230785

Dear Mr. Garrison:

       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
Information Technologies
                                                            and Services
cc:    Ben D. Orlanski, Esq.