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 June 16, 2025

Brian Finn
Chief Investment Officer
Findell Capital Management LLC
88 Pine Street, 22nd Fl.
New York, NY 10005

 Re: Findell Capital Management LLC
 Oportun Financial Corporation
 Additional Soliciting Material filed June 3 and 5, 2025, by Findell
Capital
 Management LLC et al.
 File No. 001-39050
Dear Brian Finn:

 We have reviewed your filings and have the following comments. In some
of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

 Please respond to these comments by providing the requested information
or advise us
as soon as possible when you will respond. If you do not believe our comments
apply to your
facts and circumstances, please tell us why in your response.

 After reviewing your response to these comments, we may have additional
comments.

General

1. The letter to shareholders issued on June 3, 2025, and filed as
additional soliciting
 material states that:

 "legacy directors who control the majority of the Board have no
lending
 experience and share close personal and professional ties with CEO
Raul
 Vazquez";
 "Mr. Vazquez has worked to destroy a great lending business";
 "the Board s self-defeating and entrenching behavior has made
it clear to us that
 the main goal of the legacy directors is not delivering stockholder
value,
 but preventing industry experience and independence from having a
real voice in
 the boardroom";
 "management decisions would have bankrupted the Company without
Findell s
 June 16, 2025
Page 2

 involvement"; and
 "[a]mong the legacy Board members, there are many overlapping
personal and
 professional relationships with each other and with CEO Vazquez
that raise
 serious questions about the ability of these directors to provide
appropriate
 oversight. For example, Mr. Vazquez is a board member of Intuit
and oversaw
 Mr. Williams and Ms. Lee in that capacity."

 Such statements appear to impugn the character, integrity and personal
reputation of
 Mr. Vazquez and the Board without adequate factual foundation. Please
do not use
 these or similar statements in soliciting materials without providing
a proper factual
 foundation for the statements. In addition, as to matters for which
the filing persons do
 have a proper factual foundation, please avoid making statements about
those matters
 that go beyond the scope of what is reasonably supported by the
factual foundation.
 Please note that characterizing a statement as one s opinion or
belief does not
 eliminate the need to provide a proper factual foundation for the
statement; there must
 be a reasonable basis for each opinion or belief that the filing
persons express. Please
 refer to Note (b) to Rule 14a-9.
Additional Soliciting Material filed June 5, 2025
Item 1

2. We note the following statements:

 "Ms. Lee and the Rest of the Legacy Directors Have Overseen
Massive Value
 Destruction and Lack Lending Experience, Making Them
Underqualified to Serve
 as Lead Independent Director";
 "the legacy directors [ ] collectively appear interested only in
entrenching
 themselves and ignoring the best interests of Oportun"; and
 "these legacy directors are unqualified to serve on this board,
let alone serve as
 lead independent director."

 Refer to our prior comment above. Please do not use these or similar
statements in
 your filings without providing a proper factual foundation. Please
refer to filing
 persons' obligations under Exchange Act Rule 14a-9.

 We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.
 June 16, 2025
Page 3

 Please direct any questions to Laura McKenzie at 202-551-4568 or Perry
Hindin at
202-551-3444 .

 Sincerely,

 Division of Corporation
Finance
 Office of Mergers &
Acquisitions
cc: Andrew Freedman
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