United States securities and exchange commission logo

August 20, 2021

William Horne
Chief Executive Officer
Ault Disruptive Technologies Corp
11411 Southern Highlands Parkway, Suite 240
Las Vegas, Nevada 89141

Re: Ault Disruptive
Technologies Corp
Amendment No. 1 to
Draft Registration Statement
Submitted July 26,
2021
CIK No. 0001864032

Dear Mr. Horne:

We have conducted a limited review of your draft registration
statement. In our
comment, we may ask you to provide us with information so we may better
understand your
disclosure.

Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.

After reviewing the information you provide in response to our
comment and your
amended draft registration statement or filed registration statement, we
may have additional
comments.

Amendment #1 to Draft Registration Statement filed July26, 2021

Capitalization, page 88

1. We note that you are offering 10,000,000 Class A shares as part of your initial public offering of units, but footnote 2 suggests you will show less than all Class A shares subject to possible redemption in your Capitalization table. Please tell us how you considered the guidance in ASC 480-10-S99-3A, which requires securities that are redeemable for cash or other assets to be classified outside of permanent equity if they are redeemable (1) at a fixed or determinable price on a fixed or determinable date, (2) at the option of the holder, or (3) upon the occurrence of an event that is not solely within the control of the issuer, in concluding that all 10,000,000 Class A shares were not required to be presented outside of permanent equity and part of shares subject to possible William Horne Ault Disruptive Technologies Corp August 20, 2021

redemption. 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.

We request that you publicly file your registration statement and nonpublic draft
submissions at least 15 days prior to any road show as that term is defined in Rule 433(h)(4) or,
in the absence of a road show, at least 15 days prior to the requested effective date of the
registration statement. Refer to Rules 460 and 461 regarding requests for acceleration.

You may contact Howard Efron at 202-551-3439 or Wilson Lee at 202-551-3468 if you
have questions regarding comments on the financial statements and related matters. Please
contact Patrick Costello at 202-551-8742 or Pam Long at 202-551-3765 with any other
questions.

Sincerely, FirstName LastNameWilliam Horne
Division of Corporation Finance
Comapany NameAult Disruptive Technologies Corp Office of Real Estate & Construction
August 20, 2021 Page 2
cc: Spencer G. Feldman, Esq.
FirstName LastName