0001564590-18-015745.txt : 20180718 0001564590-18-015745.hdr.sgml : 20180718 20180618160557 ACCESSION NUMBER: 0001564590-18-015745 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20180618 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SMITH MICRO SOFTWARE INC CENTRAL INDEX KEY: 0000948708 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-PREPACKAGED SOFTWARE [7372] IRS NUMBER: 330029027 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 51 COLUMBIA CITY: ALISO VIEJO STATE: CA ZIP: 92656 BUSINESS PHONE: 9493625800 MAIL ADDRESS: STREET 1: 51 COLUMBIA CITY: ALISO VIEJO STATE: CA ZIP: 92656 CORRESP 1 filename1.htm smsi-corresp.htm

 

June 18, 2018

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Mail Stop 4561

Washington, D.C.  20549-4631

 

Attention:Jan Woo, Legal Branch Chief

Michael Foland, Attorney-Advisor

 

Re:Acceleration Request of Smith Micro Software, Inc.

Registration Statement on Form S-3, Filed June 1, 2018

File No. 333-225389

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Smith Micro Software, Inc. (the “Company”) respectfully requests that the Staff of the Division of Corporation Finance of the Securities and Exchange Commission accelerate the effective date of the Company’s Registration Statement on Form S-3 (Registration No. 333-225389) (the “Registration Statement”), so that it will be declared effective at 5:00 p.m., Eastern time, on June 19, 2018, or as soon as practicable thereafter. The Company authorizes Jennifer Minter and Brian Novosel of Buchanan Ingersoll & Rooney PC, counsel to the Company, to orally modify or withdraw this request for acceleration.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would inform Jennifer Minter of Buchanan Ingersoll & Rooney PC, counsel to the Company, at (412) 562-8444.

 

 

Sincerely,

 

Smith Micro Software, Inc.

 

By:      /s/ Timothy C. Huffmyer

Chief Financial Officer

 

 

 

 

cc:William W. Smith, Jr., Chief Executive Officer