Graubard Miller The Chrysler Building 405 Lexington Avenue New York, N.Y. 10174-1101 (212) 818-8800 |
Facsimile | Direct Dial Number | |
| (212) 818-8881 | (212) 818-8638 | |
| Email Address | ||
| jgallant@graubard.com |
January 13, 2015
Matthew Crispino, Esq.
Attorney-Advisor
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Kitara Holdco Corp. | |
| Amendment No. 2 to Registration Statement on Form S-4 | ||
| Filed December 29, 2014 | ||
| File No. 333-199892 |
Dear Mr. Crispino:
On behalf of Kitara Holdco Corp. (the “Company” or “Holdco”), we respond as follows to the Staff’s verbal comment, received on January 8, 2015, relating to the above-captioned Registration Statement on Form S-4. We have paraphrased the Staff’s comment below and provided the Company’s response immediately thereafter.
Provide a detailed written description of the process by which Future Ads delivers ads to users, including its relationship with its advertisers and its third party app owners.
The Company has submitted the requested description supplementally to Ms. Chris Davis.
* * * * * * *
If you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.
| Sincerely, | |
| /s/ Jeffrey M. Gallant | |
| Jeffrey M. Gallant |
| cc: | Mr. Robert Regular |
