Alexander Capital L.P.
17 State Street, 5th Floor
New York, NY 10004
April 26, 2022
Via Edgar
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Attn: Gregory Herbers
| Re: | SOBR Safe, Inc. |
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| Registration Statement on Form S-1 |
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| File No. 333-262665 |
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| Request for Acceleration |
Dear Mr. Herbers:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representative of the underwriters of the proposed public offering of SOBR Safe, Inc. (the “Company”) hereby join the Company’s request that the effective date of the Company’s Registration Statement on Form S-1 (File No. 333-262665) (the “Registration Statement”) be accelerated so that the Company’s Registration Statement will become effective at 5:00 PM, Eastern time, on Wednesday, April 27, 2022, or as soon as thereafter as is practicable.
Pursuant to Rule 460 under the Securities Act, we, as representative of the underwriters, wish to advise you that there will be distributed to each underwriter, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.
The undersigned advises that it has complied and will continue to comply, and that it has been informed by the participating underwriters and dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
Please feel free to direct any questions or comments concerning this request to Jonathan Gazdak at Alexander Capital L.P. at (646) 787-8898.
| Sincerely, |
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Alexander Capital L.P. | |||
/s/ Jonathan Gazdak | |||
| By: | Jonathan Gazdak | |
Its: | Managing Director | ||