Shift Technologies, Inc.
2525 16th Street, Suite 316
San Francisco, CA 94103-4234
December 1, 2020
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Shift Technologies, Inc. | |
| Registration Statement on Form S-1 | ||
| File No. 333-249786 |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Shift Technologies, Inc. (the “Registrant”) hereby requests that the above-referenced registration statement on Form S-1 (File No. 333-249786) (the “Registration Statement”) be declared effective on December 3, 2020, at 4:00 p.m., Eastern Time, or as soon thereafter as is practicable or at such later time as the Registrant may orally request via telephone call to the staff of the Commission prior to such time. The Registrant hereby authorizes each of Martin C. Glass and Jeffrey R. Shuman of Jenner & Block LLP, counsel to the Registrant, to make such request on its behalf.
Once the Registration Statement has been declared effective, please orally confirm that event with Martin C. Glass of Jenner & Block LLP, counsel to the Registrant, at (212) 891-1672, or in his absence, Jeffrey R. Shuman at (312) 840-8695.
[Signature Page Follows]
| Sincerely, | |
| /s/ George Arison | |
George Arison Co-Chief Executive Officer and Chairman |
| cc: | Amanda Bradley, Esq. Martin C. Glass, Esq. |
| Jeffrey R. Shuman, Esq. |
