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U.S. Securities and Exchange Commission

Securities Act of 1933 - Rule 144(d)

May 16, 2007

Response of the Office of Chief Counsel
Division of Corporation Finance


Smart Move, Inc.
Incoming letter dated January 31, 2007

Based on the facts presented, it is the Division's view that the holders of the membership interests of A Smart Move, L.L.C. may not "tack" the period during which they held those interests to their holding period for the shares of Smart Move, Inc. for purposes of determining their holding period for resales under Rule 144.

This position is based on the representations made to the Division in your letter. Any different facts or conditions might require a different conclusion.


Mark F. Vilardo
Special Counsel

Incoming Letter:

The Incoming Letter is in Acrobat format.


Modified: 05/16/2007