SecProbe.io

CORRESP
1
filename1.htm

April
20, 2020

Office
of Technology

Division
of Corporation Finance

Securities
and Exchange Commission

100
F. Street, NE

Washington,
DC 20549

 Re: SavvyShares
LLC

Amendment
No. 1 to Draft Offering Statement on Form 1-A

Submitted
March 23, 2020

CIK
No. 0001801255

Ladies
and Gentlemen:

This
letter sets forth the responses of SavvyShares LLC, a Delaware limited liability company (the “Company,” “SavvyShares”
or “we”), to the comments received from the Staff of the Division of Corporation Finance (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) by letter dated April 3, 2020 (the “Comment
Letter”) concerning the Company’s draft offering statement on Form 1-A. In conjunction with this letter, the Company
is submitting an amended draft offering statement on Form 1-A (the “Offering Statement”) to the Commission.
For convenient reference, we have set forth below in bold each of the Staff’s comments set forth in the Comment Letter and
have set forth our responses to the numbering of the comments and the headings used in the Comment Letter.

Amendment
No. 1 to Draft Offering Statement on Form 1-A

Description
of Business

Competition,
page 26

 1. You
                                         disclose that you believe your single-source digital tracking technology will provide
                                         you with a competitive advantage. In this regard, we note from your website that Luth
                                         Research, your founder and competitor, has comparable tracking technology (“SavvyConnect”)
                                         that it launched in 2009. If true, please identify Luth Research as a competitor in digital
                                         tracking and address the risks and challenges that you may face as a result of such competition.

Response:
We note the Staff’s comment. We have identified Luth Research as a competitor in digital tracking and have addressed
the risks and challenges that we may face as a result of such competition in the Offering Statement.

***

If you have any further comments and/or questions, please contact me or John Tishler, Esq. at Sheppard, Mullin, Richter &
Hampton LLP at (858) 720-8943.

    Very
    truly yours,

    /s/
    Roseanne Luth

    Roseanne
    Luth

    Chief
    Executive Officer

    cc:
    John
    Tishler, Esq., Sheppard, Mullin, Richter & Hampton LLP