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


    DIVISION OF
CORPORATION FINANCE
                                                                    April 6,
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
                  PRRN14A filed by Driver Management Company LLC, et al.
                  Filed April 3, 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. The approximate date upon which the proxy statement is expected to be
released to security
     holders appears to be placed on page two of the proxy statement. This
expected date,
     however, is required to be placed on the first page pursuant to Item 1(b)
of Schedule 14A.
     Please revise.

  Ms. Rodeheaver has clear conflicts of interest..., page 25

  2. The rationale offered in support of Driver's belief that Ms. Rodeheaver
has a significant
     interest in "the trappings of her position" is subjective and potentially
cannot serve as
     "evidence." Given that the possibility exists that First United  and by
extension,
     shareholders  conceivably could benefit from her purported vigorous
pursuit of senior
     leadership positions at industry trade and lobbying groups, please clarify
the meaning of
     "trappings" and offer objectively determinable "evidence." Alternatively,
please delete the
     assertion. See Note b. to Rule 14a-9.
 J. Abbott R. Cooper
April 6, 2020
Page 2

First United's Lead Director is a poor substitute for an independent Chair,
page 27

3. The assertion that Mr. McCullough, First United's Lead Director, has been
absent and
   inaccessible has been contradicted by several statements indicating that
letters signed by him,
   as well as a phone call, had been received, and a meeting involving him was
declined. In
   order to comply with Rule 14a-9, please revise to reconcile these
inconsistencies.

Proposal No. 1 | Election of Directors, page 34

4. The participants have nominated three director candidates notwithstanding
the fact that First
   United's preliminary proxy statement includes four nominees for the Board of
Directors.
   Please clarify the participant's reasons for nominating fewer than four
nominees. See Item
   7(b) of Schedule 14A and Instruction 4 to paragraph (a) of Item 401 of
Regulation S-K.

5. Notwithstanding the disclosure in form of proxy, please disclose in the
proxy statement that
   no assurance can be given that the registrant's nominees will serve if
elected with any of the
   soliciting party's nominees. See Rule 14a-4(d)(4)(iv).

Form of Proxy

6. Multiple instances exist in which representation are made that the
solicitation is being
   conducted on behalf of "Driver," which is defined in the proxy card as
"Driver Opportunity
   Partners I LP." This disclosure conflicts with the disclosure in boldface
type that the
   solicitation is being conducted on behalf of all participants. For example,
the disclosure
   indicates that the "Proxy will only be valid in connection with Driver's
solicitation of proxies
   for the Annual Meeting." Please revise to remove this apparent
inconsistency, or advise.


                                         *        *     *

        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
cc: Andrew Freedman, Esq.
Olshan Frome Wolosky LLP