Securities Act of 1933 - Rule 144(d)

May 16, 2007

Response of the Office of Chief Counsel
Division of Corporation Finance

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.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2007/smartmove051607-144.htm