SEC Company Response from MARA Holdings, (MARA) — Oct 11, 2017
MARA Holdings, Inc.
Date: Oct. 11, 2017 · CIK: 0001507605 · Accession: 0001493152-17-011511
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CORRESP
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October
11, 2017
Securities
and Exchange Commission
Division
of Corporate Finance
100
F Street, NE
Washington,
D.C. 20549
Attn:
Mr. Bernard Nolan
Re:
Marathon Patent
Group, Inc.
Registration Statement on Form S-3
Filed September 13, 2017
File No. 333- 220438
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 October 13, 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