UNITED STATES
                                  SECURITIES AND EXCHANGE COMMISSION
                                               WASHINGTON, D.C. 20549


    DIVISION OF
CORPORATION FINANCE
                                                                       March
26, 2020


  J. Abbott R. Cooper
  Managing Member
  Driver Management Company LLC
  250 Park Avenue   7th Floor
  New York, New York 10177

          Re:     First United Corporation
                  PREC14A filed by Driver Management Company LLC, et al.
                  Filed March 26, 2020
                  File No. 000-14237

  Dear Mr. Cooper:

          We have reviewed the above-captioned filing, and have the following
comments. Some
  of our comments may ask for additional information so we may better
understand the disclosure.

         Please respond to this letter by amending the filing and/or by
providing the requested
  information. If you do not believe our comments apply to your facts and
circumstances and/or
  do not believe an amendment is appropriate, please tell us why in a written
response.

         After reviewing any amendment to the filing and any information
provided in response to
  these comments, we may have additional comments.

  Preliminary Proxy Statement filed under cover of Schedule 14A

  General

  1. Please refer to the following statement appearing on page two: "[a]s of
the date hereof", the
     participants beneficially owned 366,212 shares of Common Stock. Assuming
that the term
     "hereof" as used in this context relates to the approximate date upon
which the proxy
     statement is expected to be mailed, and that date is at present unknown,
please advise us,
     with a view toward revised disclosure, how this amount will be affirmed.

  2. Please advise us when the participants anticipate distributing their proxy
statement. Given
     that reliance on Rule 14a-5(c) is impermissible at any time before the
registrant distributes its
     proxy statement, the participants will accept all legal risk in connection
with distributing the
     initial definitive proxy statement without all required disclosures and
should undertake to
     subsequently provide any omitted information in a supplement in order to
mitigate that risk.
 J. Abbott R. Cooper
March 26, 2020
Page 2

Voting and Proxy Procedures, page 40

3. The participants' position with respect to how shares will be voted on the
second proposal is
   indeterminable and thus inconsistent with the requirements specified within
Rule 14a-
   4(b)(1). To the extent the participants intend to use the discretionary
authority to vote
   uninstructed proxy cards under that rule provision, "the form of proxy
[must] state[ ] in bold-
   face type how [the participants] intend[ ] to vote the shares..." Please
revise.

Incorporation by Reference, page 44

4. Rule 14a-5(c) permits information to be omitted if a clear reference is made
to the document
   containing such information. The information is not "incorporated by
reference" as the title
   to this section indicates. Please revise, especially given that Instruction
D to Schedule 14A
   governs incorporation by reference. In addition, due to need for the
participants to comply
   with Rule 14a-3(a)(1), please disclose the specific line items within
Schedule 14A the
   participants have seemingly sought to satisfy by referencing First United's
proxy statement
   through ostensible reliance upon Rule 14a-5(c).

Form of Proxy

5. Please refer to the following representation: "DRIVER [MAKES NO
   RECOMMENDATION WITH RESPECT TO PROPOSALS 2 AND 3]". To the extent that
   the participants intend to exercise discretionary authority under Rule
14a-4(b)(1) with respect
   to proposals two and three, please advise us why the participants appear to
be contemplating
   a recommendation with respect to each of those proposals. Notwithstanding
the placeholders
   within the brackets, other disclosure suggests that the participants have
reserved the right to
   vote "For" the third proposal and might vote "For" the second as well if a
choice has not
   been specified on the form of proxy. As an indication that the proxy would
be voted "For"
   either of these proposals could be interpreted as a recommendation to vote
in favor of such
   proposals, please revise to remove this implication even if the disclosure
is now tentative.

                                         *      *       *

        We remind you that the participants are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

        You may contact me at (202) 551-3266 with any questions.

                                                            Sincerely,

                                                            /s/ Nicholas P.
Panos

                                                            Nicholas P. Panos
                                                            Senior Special
Counsel
                                                            Office of Mergers
and Acquisitions
 J. Abbott R. Cooper
March 26, 2020
Page 3

cc: Andrew Freedman, Esq.
Olshan Frome Wolosky LLP