SEC Company Response from SMITH MICRO SOFTWARE, INC. (SMSI) (CIK 0000948708) (SMSI) — Oct 5, 2016
SMITH MICRO SOFTWARE, INC. (SMSI) (CIK 0000948708)
Date: Oct. 5, 2016 · CIK: 0000948708 · Accession: 0001193125-16-731752
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File numbers found in text: 333-213778
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CORRESP 1 filename1.htm CORRESP SMITH MICRO SOFTWARE, INC. 51 Columbia, Suite 200 Aliso Viejo, CA 92656 October 5, 2016 Filed via Edgar U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549 Re: Smith Micro Software, Inc. Registration Statement on Form S-3 (File No. 333-213778) Acceleration Request Requested Date: Friday, October 7, 2016 Requested Time: 10:00 a.m. Eastern Time Ladies and Gentlemen: Smith Micro Software, Inc. (the “Registrant”) hereby requests, in accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, that the Securities and Exchange Commission (the “Commission”) take appropriate action to make the Registrant’s Registration Statement on Form S-3 (File No. 333-213778) effective at the Requested Date and Requested Time as set forth above, or as soon thereafter as practicable. In delivering such request, the Registrant acknowledges and agrees that: • should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; • the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and • the Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please advise the undersigned at (949) 362-2393 or via email at syasbek@smithmicro.com when the order permitting such Registration Statement to become effective is issued. Very truly yours, SMITH MICRO SOFTWARE, INC. By: /s/ Steven M. Yasbek Steven M. Yasbek Chief Financial Officer cc: Allen Z. Sussman, Esq., Loeb & Loeb LLP