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Roth Capital Partners, LLC

Maxim Group LLC

c/o Roth Capital Partners, LLC

888 San Clemente Drive

Newport Beach, CA 92660

October
16, 2017

VIA EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100 F
Street, NE

Washington,
D.C. 20549

Attention:
Jan Woo

Re:

RumbleOn,
Inc. (the “Company”)

Registration
Statement on Form S-1, as amended (“Registration
Statement”)

File
No. 333-220308

Ladies
and Gentlemen:

Pursuant to Rule
461 of the General Rules and Regulations of the U.S. Securities and
Exchange Commission under the Securities Act of 1933, as amended
(the “Securities Act”), Roth Capital Partners, LLC and
Maxim Group LLC, as representatives of the underwriters, hereby
join in the Company’s request for acceleration of the
effective date of the above-referenced Registration Statement so
that it will become effective at 2:00 p.m., Eastern Time, on
Wednesday, October 18, 2017, or as soon thereafter as
practicable.

Pursuant to Rule
460 under the Securities Act, please be advised that during the
period from September 28, 2017 to the date of this letter, we,
acting on behalf of the several underwriters, distributed as many
copies of the Preliminary Prospectuses, dated September 28, 2017,
as appears to be reasonable to secure adequate distribution of the
Preliminary Prospectus.

The
undersigned confirms that it has complied with and will continue to
comply with, and it has been informed or will be informed by
participating dealers that they have complied with or will comply
with, Rule 15c2-8 promulgated under the Securities Exchange Act of
1934, as amended, in connection with the above-referenced
issue.

ROTH
CAPITAL PARTNERS, LLC

By: /s/ Aaron M.
Gurewitz

Name:
Aaron M. Gurewitz

Title:
Head of Equity Capital Markets

MAXIM
GROUP LLC

By: /s/ Clifford
Teller

Name:
Clifford Teller

Title:
Executive Managing Director, Head of Investment
Banking