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SEC Comment Letter for Sphere 3D Corp. (ANY) (CIK 0001591956) (DRK) — Jul 28, 2017

Sphere 3D Corp. (ANY) (CIK 0001591956)
Date: July 28, 2017 · CIK: 0001591956 · Accession: 0000000000-17-026706

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File numbers found in text: 333-219383

Date
July 20, 2017
Author
/s/ Jan Woo
Form
UPLOAD
Company
Sphere 3D Corp. (ANY) (CIK 0001591956)

Letter

July 28 , 2017 Mail Stop 4561 Eric L. Kelly Sphere 3D Corp. Chief Executive Officer 9112 Spectrum Center Boulevard San Diego, CA 92123

Re: Sphere 3D Corp. Registration Statement on Form F-3 Filed July 20, 2017 File No. 333-219383

Dear Mr. Kelly :

This is to advise you that we have not reviewed and will not review your registration statement .

Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Edwin Kim, Attor ney-Advisor, at (202) 551 -3297 or me at (202) 551 -3453 with any questions.

Sincerely,
/s/ Jan Woo

Show Raw Text
July 28 , 2017
Mail Stop 4561

Eric L. Kelly
Sphere 3D Corp.
Chief Executive Officer
9112 Spectrum Center Boulevard
San Diego, CA  92123

Re: Sphere 3D Corp.
  Registration Statement on Form F-3
Filed  July 20, 2017
  File No.  333-219383

Dear Mr. Kelly :

This is to advise you that we have not reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please  contact Edwin Kim, Attor ney-Advisor,  at (202) 551 -3297 or me at (202) 551 -3453
with any questions.

Sincerely,

 /s/ Jan Woo

Jan Woo
Branch Chief - Legal
Office of Information Technologies
and Services

cc: Eric Sibbitt , Esq.
O’Melveny & Myers LLP