0001213900-23-005337.txt : 20230321 0001213900-23-005337.hdr.sgml : 20230321 20230126161648 ACCESSION NUMBER: 0001213900-23-005337 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20230126 FILER: COMPANY DATA: COMPANY CONFORMED NAME: KLUDEIN I ACQUISITION CORP CENTRAL INDEX KEY: 0001826671 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-COMPUTER PROCESSING & DATA PREPARATION [7374] IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 855 EL CAMINO REAL NUM 13A-385 CITY: PALO ALTO STATE: CA ZIP: 94301 BUSINESS PHONE: 4155092370 MAIL ADDRESS: STREET 1: 855 EL CAMINO REAL NUM 13A-385 CITY: PALO ALTO STATE: CA ZIP: 94301 CORRESP 1 filename1.htm

 

KludeIn I Acquisition Corp.

1096 Keeler Avenue

Berkeley, CA 94708

 

VIA EDGAR

 

January 26, 2023

 

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Technology

Washington, D.C. 20549

Attn: Mr. Matthew Crispino

 

  Re: Re: KludeIn I Acquisition Corp.
    Amendment No. 6 to Registration Statement on Form S-4
    Filed January 17, 2023
    File No. 333-265952

 

Dear Mr. Crispino

 

KludeIn I Acquisition Corp. (the “Company,” “KludeIn,” “we,” “our” or “us”) hereby transmits the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), on January 24, 2023, regarding the Amendment No. 6 to Registration Statement on Form S-4 submitted to the Commission on January 17, 2022. For the Staff’s convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response.

 

Amendment No. 6 to Form S-4

Basis of Presentation and Glossary, page 2

 

1.Please revise your definition of minimum cash condition here to disclose the revised terms as amended pursuant to the January 17, 2023 amendment to the Merger Agreement.

 

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has updated its disclosure on page 4.

 

Summary of the Proxy Statement/Prospectus

Waiver of Certain Lock-Up Restrictions, page 18

 

2.Please revise to explain how releasing the Near securities from the lock-up restrictions assists KludeIn with satisfying Nasdaq listing requirements.

 

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has updated its disclosure on pages 18, 121 and 135.

 

Executive Compensation of Near, page 266

 

3.Please update this section to disclose compensation paid to Near’s executives for the year ended December 31, 2022.

 

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has updated its disclosure on pages 266 - 268.

 

****

 

 

 

 

We thank the Staff for its review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact to our counsel, Benjamin Reichel at breichel@egsllp.com or by telephone at (212) 370-1300.

 

  Sincerely,
   
  /s/ Mini Krishnamoorthy
  Mini Krishnamoorthy, Chief Financial Officer of KludeIn I Acquisition Corp.
   
cc: Ellenoff Grossman & Schole LLP