Friday, April 27, 2007
Elaine Wolff
U.S. Securities & Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Smart Holdings, Inc.
Commission File No.: 333-140810
Dear Ms. Wolff:
Pursuant to Rule 461(a) of Regulation C, as promulgated under the Securities Act of 1933, acceleration of the Registration Statement of Smart Holdings, Inc. is hereby requested to 10:00 a.m. on May 1, 2007.
Registrant acknowledges the following:
1) | Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing. |
2) | The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
3) | The company may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Thank for your cooperation in this matter.
Dutifully,
Goldberg Law Group, P.A.
s/ Glenn Goldberg_
Glenn Goldberg Esq.