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SEC Company Response from MARA Holdings, (MARA) — May 10, 2017

MARA Holdings, Inc.
Date: May 10, 2017 · CIK: 0001507605 · Accession: 0001104659-17-031598

AI Filing Summary & Sentiment

File numbers found in text: 333-216004

Date
May 10, 2017
Author
Not clearly detected
Form
CORRESP
Company
MARA Holdings, Inc.

Letter

Re: Marathon Patent Group, Inc.

May 10, 2017

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, NE

Washington, D.C. 20549

Attn: —Gabe Eckstein

Registration Statement on Form S-1

Filed May 10, 2017

File No. 333-216004

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Marathon Patent Group, Inc. (the “Company”) respectfully requests that the effective date of the registration statement referred to above be accelerated so that it will become effective at 4:15 p.m., Eastern Standard Time, on May 12, 2017, or as soon thereafter as possible.

The Company hereby acknowledges the following:

· 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 Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

· the Company 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.

MARATHON PATENT GROUP, INC.

By: /s/ Francis Knuettel II

Name: Francis Knuettel II

Title: Chief Financial Officer

Show Raw Text
CORRESP
1
filename1.htm

May 10, 2017

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, NE

Washington, D.C. 20549

Attn: —Gabe Eckstein

Re: Marathon Patent Group, Inc.

Registration Statement on Form S-1

Filed May 10, 2017

File No. 333-216004

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Marathon Patent Group, Inc. (the “Company”) respectfully requests that the effective date of the registration statement referred to above be accelerated so that it will become effective at 4:15 p.m., Eastern Standard Time, on May 12, 2017, or as soon thereafter as possible.

The Company hereby acknowledges the following:

·              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 Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·              the Company 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.

MARATHON   PATENT GROUP, INC.

By:   /s/ Francis Knuettel II

Name: Francis   Knuettel II

Title:  Chief Financial Officer