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SEC Company Response from MARA Holdings, (MARA) — Oct 11, 2017

MARA Holdings, Inc.
Date: Oct. 11, 2017 · CIK: 0001507605 · Accession: 0001493152-17-011511

AI Filing Summary & Sentiment

Date
September 13, 2017
Author
Not clearly detected
Form
CORRESP
Company
MARA Holdings, Inc.

Letter

Re: Marathon Patent Group, Inc.

October 11, 2017

Securities and Exchange Commission

Division of Corporate Finance

F Street, NE

Washington, D.C. 20549

Attn: Mr. Bernard Nolan

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

Show Raw Text
CORRESP
1
filename1.htm

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