SEC Company Response from SMITH MICRO SOFTWARE, INC. (SMSI) (CIK 0000948708) (SMSI) — Jun 18, 2018
SMITH MICRO SOFTWARE, INC. (SMSI) (CIK 0000948708)
Date: June 18, 2018 · CIK: 0000948708 · Accession: 0001564590-18-015745
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File numbers found in text: 333-225389
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CORRESP 1 filename1.htm smsi-corresp.htm June 18, 2018 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Mail Stop 4561 Washington, D.C. 20549-4631 Attention:Jan Woo, Legal Branch Chief Michael Foland, Attorney-Advisor Re:Acceleration Request of Smith Micro Software, Inc. Registration Statement on Form S-3, Filed June 1, 2018 File No. 333-225389 Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Smith Micro Software, Inc. (the “Company”) respectfully requests that the Staff of the Division of Corporation Finance of the Securities and Exchange Commission accelerate the effective date of the Company’s Registration Statement on Form S-3 (Registration No. 333-225389) (the “Registration Statement”), so that it will be declared effective at 5:00 p.m., Eastern time, on June 19, 2018, or as soon as practicable thereafter. The Company authorizes Jennifer Minter and Brian Novosel of Buchanan Ingersoll & Rooney PC, counsel to the Company, to orally modify or withdraw this request for acceleration. It would be appreciated if, as soon as the Registration Statement is declared effective, you would inform Jennifer Minter of Buchanan Ingersoll & Rooney PC, counsel to the Company, at (412) 562-8444. Sincerely, Smith Micro Software, Inc. By: /s/ Timothy C. Huffmyer Chief Financial Officer cc:William W. Smith, Jr., Chief Executive Officer