Yuma Delaware Merger Subsidiary, Inc.

1177 West Loop South, Suite 1825

Houston, Texas 77027

(713) 968-7000

September 21, 2016

VIA EDGAR

H. Roger Schwall

Assistant Director

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, DC 20549

Re:         Yuma Delaware Merger Subsidiary, Inc.

Registration Statement on Form S-4

File No. 333-212103

Dear Mr. Schwall:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Yuma Delaware Merger Subsidiary, Inc. (the “Company”) respectfully requests that the U.S. Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above referenced Registration Statement so that it may become effective at 5:00 p.m. Eastern Daylight Time on Thursday, September 22, 2016, or as soon thereafter as practicable. The Company would also appreciate telephone notice of such effectiveness to Reid A. Godbolt at (303) 573-1600. The Company hereby authorizes Reid A. Godbolt of Jones & Keller, P.C. to orally modify or withdraw this request for acceleration.

In connection with the Company’s request for acceleration of effectiveness of the Registration Statement, the Company acknowledges the following:

(1)

Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

(2)

The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

(3)

The Company may not asset staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Very truly yours,

YUMA DELAWARE MERGER SUBSIDIARY, INC.

By: /s/ Sam L. Banks                                                                

Name: Sam L. Banks

Title: Chairman of the Board, President and

           Chief Executive Officer