February 26, 2021



Via Email

James M. Turner
Sichenzia Ross Ferrence LLP
1188 Avenue of the Americas, 37th Floor
New York, NY 10036

       Re:    CCUR Holdings, Inc.
              PRER14C filed February 24, 2021
              File No. 1-37706

              Schedule 13E-3/A filed February 24, 2021
              Filed by JDS1, LLC et al.
              File No. 5-36889

Dear Mr. Turner:

       The Office of Mergers and Acquisitions has reviewed the amended filings
listed above
along with your response letter filed on the same date, and have the following
comments. All
defined terms have the same meaning as in the information statement listed
above.

Substantive Factors Favoring Fairness of the Reverse Stock Split, page 22

   1. We note that the price per share to be paid in the reverse stock split
has been reduced
      from $3.06 per share to $2.86 per share. The filing persons have
determined the reduced
      price to be fair, based in part on the decline in the Company   s stock
price since January
      26, 2021, when it announced a loss of approximately $14 million in escrow
funds due to
      a theft by an employee at Wright Brothers where such funds were being
held in escrow.
      However, on page 43 of the information statement, you state that you are
pursuing
      insurance and legal actions against those parties responsible for the
losses. Provide
      further details about the potential for recovery through insurance or by
litigation, and note
      how the filing persons considered (or did not consider) the possibility
of recovering the
      stolen funds in their fairness determination.

Annex A     Opinion of Valuescope

   2. The report of Valuescope dated February 15, 2021 states that its fairness
determination is
      based in part on discussions with management    regarding past and
current performance
 James M. Turner, Esq.
Sichenzia Ross Ferrence LLP
February 26, 2021
Page 2

       and prospects for the Company.    Summarize any non-public forecasts or
projections
       provided by management to Valuescope and used in its fairness analysis.

   3. See our last comment above. Include a summary of the material assumptions
underlying
      any such forecasts or projections.

   4. See comment 1 above. Revise to note whether (and if so, how) Valuescope
considered
      the possibility of recovery of the stolen funds in determining the
fairness of the reduced
      per share price to be paid in the reverse stock split.

       We remind you that the Company and other filing persons on the Schedule
13E-3 are
responsible for the accuracy and adequacy of their disclosures in both filings,
notwithstanding
any review, comments, action or absence of action by the staff.

       Please contact me at 202-551-3263 with any questions.


                                                            Sincerely,

                                                            /s/ Christina Chalk

                                                            Christina Chalk
                                                            Senior Special
Counsel
                                                            Office of Mergers &
Acquisitions