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                              February 22, 2023

       Joshua Apfelroth
       Partner
       Proskauer Rose LLP
       Eleven Times Square
       New York, NY 10036

                                                        Re: Ritchie Bros
Auctioneers Inc.
                                                            Definitive
Additional Soliciting Materials
                                                            Filed February 17,
2023 by Luxor Capital Group, LP et. al.
                                                            File No. 001-13425

       Dear Joshua Apfelroth:

              We have reviewed your filing 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.

       Definitive Additional Soliciting Materials

       RBA Shareholders Presentation

   1.                                                   We note, in slide 9,
that you state that    if the deal is voted down, RBA stock will
                                                        soar.    The inclusion
of valuations in soliciting materials is only appropriate and consonant
                                                        with Rule 14a-9 when
made in good faith and on a reasonable basis and where
                                                        accompanied by
disclosure which facilities shareholders    understanding of the basis for
                                                        and the limitations on
the projected realizable values. See Exchange Act Release No.
                                                        16833 (May 23, 1980).
Please provide us with your analysis supporting your statement
                                                        and confirm that in
future filings in which you provide similar disclosure you will include
                                                        a similar analysis. To
the extent the information in slide 26 provides support for your
                                                        statement, please
provide us with support for slide 26.
   2.                                                   You must avoid issuing
statements that directly or indirectly impugn the character,
                                                        integrity or personal
reputation or make charges of illegal, improper or immoral conduct
                                                        without factual
foundation. Provide us supplementally, or disclose, the factual foundation
 Joshua Apfelroth
Proskauer Rose LLP
February 22, 2023
Page 2
         for your statements listed below. In this regard, note that the
factual foundation for such
         assertions must be reasonable. Refer to Rule 14a-9.

                Slide 12: your page header: "Fabricated forecast used by RBA
management to
              manipulate and shortchange RBA investors" and the last bullet
point in the slide.
                Slide 74: the fourth bullet point.
3.       Each statement or assertion of opinion or belief must be clearly
characterized as such, and
         a reasonable factual basis must exist for each such opinion or belief.
Support for opinions
         or beliefs should be self-evident, disclosed in the proxy statement or
provided to the staff
         on a supplemental basis. We note your disclosure, on slide 12, stating
   if RBA had used
         its original forecast, based on their advisors    methodology, its
Board would not have been
         able to obtain the fairness opinions.
4.       Please provide us support for your disclosure about the four
investment banks    analyses,
         including their names.
        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.

         Please direct any questions to Dan Duchovny at 202-551-3619.



FirstName LastNameJoshua Apfelroth                              Sincerely,
Comapany NameProskauer Rose LLP
                                                                Division of
Corporation Finance
February 22, 2023 Page 2                                        Office of
Mergers & Acquisitions
FirstName LastName