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May 2, 2024
Andrew Kuhn
General Partner
Focused Compounding Fund, LP
3838 Oak Lawn Avenue, Suite 1000
Dallas, TX 75219
Re:Focused Compounding Fund, LP
Parks! America, Inc.
Revised Preliminary Proxy Statement on Schedule 14A filed April 30, 2024 by
Focused Compounding Fund, LP, Geoff Gannon, Andrew Kuhn, Jacob
McDonough, and Ralph Molina
File No. 000-51254
Dear Andrew Kuhn:
            We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comments apply to your facts
and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Revised Preliminary Proxy Statement filed April 30, 2024
Votes Required for Approval, page 22
1.We note your revised disclosure in this section and on page 17 regarding "broker non-
votes, if any" (emphasis added). Per your response to our prior comment 5, brokers do not
have discretionary voting authority with respect to any of the proposals so there should be
no broker non-votes. Please revise your disclosure accordingly or advise.
Solicitation of Proxies, page 24
2.We note your response to our prior comment 7. Given your prior disclosure that
employees of the Focused Compounding Group would solicit proxies, please confirm in
your response that your revised disclosure complies with the requirement under Item
4(b)(2) of Schedule 14A to "describe the class or classes of employees [employed to

 FirstName LastNameAndrew Kuhn
 Comapany NameFocused Compounding Fund, LP
 May 2, 2024 Page 2
 FirstName LastName
Andrew Kuhn
Focused Compounding Fund, LP
May 2, 2024
Page 2
solicit security holders] and the manner and nature of their employment for such purpose."
Alternatively, provide such disclosure.
General
3.We note that, in response to our prior comment 6, the definition of "Participant" now
includes Focused Compounding, which is defined as "Focused Compounding Fund, LP . .
. (together with its affiliates)." To the extent there are any such affiliates, they must be
included on the cover page of the Schedule 14A and the disclosure required under Item
5(b) of Schedule 14A must be provided with respect to each affiliate. If there are no such
affiliates, please revise accordingly.
4.We note your disclosure throughout the proxy statement (e.g., on pages 1 and 11) that
shareholders "may also vote for or against up to three (3) of the Company's six (6)
nominees." Please clarify your description of the voting options to avoid any implication
that shareholders cannot vote on your proxy card for or against as many Company
Nominees as they wish, provided they do not vote for more than seven nominees overall.
5.Refer to your disclosure on pages 3, 16, and 21 and on the proxy card that under-voted
proxies "will be voted only as directed, and 'against' the other nominees." Please provide
your detailed legal analysis for how this approach is consistent with CDI Question
139.08.
6.Please list the Company Nominees in alphabetical order by last name. See Rule 14a-
19(e)(4).
            We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please direct any questions to Laura McKenzie at 202-551-4568 or Perry Hindin at 202-
551-3444.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions
cc:       Adam Finerman