SEC Comment Letter 0000000000-23-005386 to SHIFT TECHNOLOGIES, INC. (SFTGQ) (CIK 0001762322)
SHIFT TECHNOLOGIES, INC. (SFTGQ) (CIK 0001762322)
Date: May 19, 2023 · CIK: 0001762322 · Accession: 0000000000-23-005386
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo May 19, 2023 Yi (Tiffany) Liu Associate Robinson & Cole LLP 666 Third Avenue, 20th Floor New York, NY 10017 Re:Shift Technologies, Inc. Schedule 13D filed by Maruthi J.D. Venkata Filed April 26, 2023 File No. 005-90966 Dear Yi (Tiffany) Liu: We have reviewed the above-captioned filing, and have the following comment. Please respond to this letter by amending the filing or by providing the requested information. If a belief exists that our comment does not apply to the facts and circumstances or that an amendment is inappropriate, please advise us why in a response letter. After reviewing any amendment to the filing and any information provided in response to this comment, we may have additional comments. Schedule 13D filed on April 26, 2023 General 1.We note the date of the event reported as requiring the filing of the Schedule 13D was March 14, 2023. Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule 13D within 10 days after the acquisition of more than five percent of a class of equity securities specified in Rule 13d-1(i). Based on the March 14, 2023 event date, the April 26, 2023 filing was not timely filed. Please advise us why the Schedule 13D was not filed within the required 10 days after the acquisition. We remind you that the filing person is responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameYi (Tiffany) Liu Comapany NameRobinson & Cole LLP May 19, 2023 Page 2 FirstName LastName Yi (Tiffany) Liu Robinson & Cole LLP May 19, 2023 Page 2 Please direct any questions to Michael Killoy at (202) 551-7576 or Nicholas Panos (202) 551-3266. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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United States securities and exchange commission logo
May 19, 2023
Yi (Tiffany) Liu
Associate
Robinson & Cole LLP
666 Third Avenue, 20th Floor
New York, NY 10017
Re:Shift Technologies, Inc.
Schedule 13D filed by Maruthi J.D. Venkata
Filed April 26, 2023
File No. 005-90966
Dear Yi (Tiffany) Liu:
We have reviewed the above-captioned filing, and have the following comment.
Please respond to this letter by amending the filing or by providing the requested
information. If a belief exists that our comment does not apply to the facts and circumstances or
that an amendment is inappropriate, please advise us why in a response letter.
After reviewing any amendment to the filing and any information provided in response to
this comment, we may have additional comments.
Schedule 13D filed on April 26, 2023
General
1.We note the date of the event reported as requiring the filing of the Schedule 13D was
March 14, 2023. Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule
13D within 10 days after the acquisition of more than five percent of a class of equity
securities specified in Rule 13d-1(i). Based on the March 14, 2023 event date, the April
26, 2023 filing was not timely filed. Please advise us why the Schedule 13D was not filed
within the required 10 days after the acquisition.
We remind you that the filing person is responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameYi (Tiffany) Liu
Comapany NameRobinson & Cole LLP
May 19, 2023 Page 2
FirstName LastName
Yi (Tiffany) Liu
Robinson & Cole LLP
May 19, 2023
Page 2
Please direct any questions to Michael Killoy at (202) 551-7576 or Nicholas Panos (202)
551-3266.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions