United States securities and exchange commission logo





                              January 22, 2024

       Andrew Kuhn
       Managing Member
       Focused Compounding Fund, LP
       3838 Oak Lawn Avenue, Suite 1000
       Dallas, TX 75219

                                                        Re: Focused Compounding
Fund, LP
                                                            Parks! America,
Inc.
                                                            Revised Preliminary
Proxy Statement on Schedule 14A filed January 19, 2024
                                                            by Focused
Compounding Fund, LP, Andrew Kuhn, Geoff Gannon and James
                                                            Ford
                                                            File No. 000-51254

       Dear Andrew Kuhn:

              We have reviewed your January 18, 2024 response to our comment
letter and the revised
       preliminary proxy statement filed on January 19, 2024 and have the
following comments.

              Please respond to this letter by providing the requested
information or advise us as soon
       as possible when you will respond. If you do not believe a comment
applies to your facts and
       circumstances, please tell us why in your response.

               After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our January 12, 2024
       letter.

       Revised Preliminary Proxy Statement on Schedule 14A

       Proposal No. 2 Removal Proposal, page 5

   1.                                                   We note your response
to prior comment 1. Please revise the first sentence of the last
                                                        paragraph of the
section entitled    The Focused Nominees    to conform to your response.
                                                        In addition, since
approval of the Removal Proposal is not conditioned upon approval of
                                                        the Bylaw Amendment
Proposal, please provide disclosure in the appropriate section of
                                                        the proxy statement to
explain what would happen if the Removal Proposal was approved
                                                        but the Bylaw Amendment
Proposal was not. In such a scenario, it appears that
                                                        shareholders would lack
the authority to elect successor directors to fill resulting
                                                        vacancies. Were that to
occur, please disclose whether the removed directors would have
                                                        the authority under
current section 4.7 of the Bylaws to elect their successors, and if not,
 Andrew Kuhn
Focused Compounding Fund, LP
January 22, 2024
Page 2
      the resulting impact on the Board   s composition. Alternatively,
disclose in all relevant
      sections, if true, that Proposals 2, 3 and 4 are cross-conditioned on
each other.
Proposal No. 3 Bylaw Amendment Proposal, page 5

2.    The Bylaw Amendment Proposal notes that vacancies on the Board may be
filled by the
      remaining directors by majority vote. Please disclose in this section the
voting standard
      applicable to a vote by shareholders to fill vacancies on the Board.
Current disclosure
      describing the proposal only states that    shareholders shall also have
the right, along with
      the Board, to elect successors       and the Bylaw Amendment itself only
refers to a    vote
      of shareholders.    Disclosure on page 8 under the section entitled
Election Proposal
      discloses the voting standard to approve the current Election Proposal,
but it does not
      indicate whether such standard applies in future scenarios where Board
vacancies are
      created by shareholders successfully voting to remove directors.
3.    We note your response to prior comment 2. Given the revised disclosure
that both
      shareholders and the Board would have the power to fill vacancies, please
disclose the
      outcome, in both the current solicitation and in future situations,
resulting from the
      scenario where the shareholders and Board vote for different directors to
fill the
      vacancies. Specify whose vote would control. Please also disclose
whether, assuming the
      Removal Proposal is approved, the removed directors will have the right
to vote to fill the
      Board   s vacancies. If the removed directors will not have such right,
please disclose the
      outcome resulting from the approval of the Removal Proposal and the lack
of approval of
      the Bylaw Amendment Proposal and the Election Proposal. For example,
disclose how
      the vacant Board would be filled, or alternatively, if true, disclose
that Proposals 2, 3 and
      4 are cross-conditioned on each other.
Quorum; Broker Non-Votes; Discretionary Voting, page 8

4.    Please supplement the disclosure in this section to clarify, consistent
with the last sentence
      of the first paragraph on page 9, that the filing persons do not expect
to receive any broker
      non-votes at the meeting.
      Please direct any questions to Perry Hindin at 202-551-3444.



                                                             Sincerely,
FirstName LastNameAndrew Kuhn
                                                             Division of
Corporation Finance
Comapany NameFocused Compounding Fund, LP
                                                             Office of Mergers
& Acquisitions
January 22, 2024 Page 2
cc:       Adam Finerman
FirstName LastName