SEC Company Response from MARA Holdings, (MARA) — Mar 8, 2011

MARA Holdings, Inc.
Date: March 8, 2011 · CIK: 0001507605 · Accession: 0001165527-11-000220

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AI Filing Summary & Sentiment

File numbers found in text: 333-171214

Date

March 8, 2011

Author

Not clearly detected

Form

CORRESP

Company

MARA Holdings, Inc.

Letter

VERVE VENTURES INC. March 8, 2011 THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION Attn: Errol Sanderson Division of Corporate Finance Mail Stop 4631 100 F. Street NE Washington, D.C. 20549-7010

Re: Verve Ventures Inc. Registration Statement on Form S-1 File No. 333-171214

Dear Errol Sanderson:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Verve Ventures Inc. (the "Company") hereby requests acceleration of the effective date of its Registration Statement on Form S-1/A to 3:00 PM EST Eastern Standard Time on March 9, 2011, or as soon thereafter as is practicable.

The Company acknowledges the following:

* 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.

Thank you for your assistance. Please call with any questions.

Verve Ventures Inc.

By: /s/ Leslie Clitheroe -------------------------------- Leslie Clitheroe Chief Executive Officer

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<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                               VERVE VENTURES INC.

March 8, 2011

THE UNITED STATES SECURITIES
AND EXCHANGE COMMISSION
Attn: Errol Sanderson
Division of Corporate Finance
Mail Stop 4631
100 F. Street NE
Washington, D.C. 20549-7010

Re: Verve Ventures Inc.
    Registration Statement on Form S-1
    File No. 333-171214

Dear Errol Sanderson:

Pursuant  to Rule 461  under  the  Securities  Act of 1933,  as  amended,  Verve
Ventures Inc. (the "Company") hereby requests acceleration of the effective date
of its Registration Statement on Form S-1/A to 3:00 PM EST Eastern Standard Time
on March 9, 2011, or as soon thereafter as is practicable.

The Company acknowledges the following:

     *    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.

Thank you for your assistance.  Please call with any questions.

Verve Ventures Inc.

By: /s/ Leslie Clitheroe
   --------------------------------
   Leslie Clitheroe
   Chief Executive Officer
</TEXT>
</DOCUMENT>

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