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SEC Comment Letter for MARA Holdings, (MARA) — Jan 18, 2018

MARA Holdings, Inc.
Date: Jan. 18, 2018 · CIK: 0001507605 · Accession: 0000000000-18-001751

AI Filing Summary & Sentiment

File numbers found in text: 001-36555

Date
January 17, 2018
Author
/s/ Jan Woo
Form
UPLOAD
Company
MARA Holdings, Inc.

Letter

Mail Stop 4561 January 17, 2018 Francis Knuettel II Chief Financial Officer Marathon Patent Group, Inc. 11601 Wilshire Blvd., Ste. 500 Los Angeles, CA 90025

Re: Marathon Patent Group, Inc. Revised Preliminary Information Statement on Schedule 14A Filed January 12, 2018 File No. 001-36555

Dear Mr. Knuettel :

We have completed our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities la ws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include the information the Securities Exchange Act of 1934 and all applicable rules require.

Please contact Ivan Griswold, Staff Attorney, at (202) 551 -3853, with any questions. If you require further assistance, you may contact t he undersigned at (202) 551 -3453 .

Sincerely,
/s/ Jan Woo

Show Raw Text
Mail Stop 4561

        January 17, 2018

Francis Knuettel II
Chief Financial Officer
Marathon Patent Group, Inc.
11601 Wilshire Blvd., Ste. 500
Los Angeles, CA 90025

Re: Marathon Patent Group, Inc.
 Revised Preliminary Information Statement on Schedule 14A
Filed January 12, 2018
File No. 001-36555

Dear Mr. Knuettel :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities la ws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing include the
information the Securities Exchange Act of 1934 and all applicable rules require.

Please contact Ivan Griswold, Staff Attorney, at (202) 551 -3853, with any questions.  If
you require further assistance, you may contact t he undersigned at (202) 551 -3453 .

        Sincerely,

        /s/ Jan Woo

        Jan Woo
        Legal Branch Chief
Office of Informat ion Technologies
and Services