February 9, 2018
Securities and Exchange Commission
100 F Street, North East
Washington, DC 20549-3030
Attention: Tom Kluck and Joshua Lobert
| Re: | Boston Omaha Corporation | |
| Registration Statement on Form S-3 (File No. 333-222853) | ||
| Acceleration Request | ||
| Requested Date: February 9, 2018 | ||
| Requested Time: 4:00 p.m. Eastern Daylight Time | ||
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Boston Omaha Corporation (the “Company”) hereby requests that the above-referenced Registration Statement on Form S-3 (File No. 333-222853) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above, or as soon as practicable thereafter.
In connection with the acceleration request, the Company hereby acknowledges that:
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should the Securities and Exchange Commission (the “Commission”) or the Staff of the Division of Corporation Finance of the Commission (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; |
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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 Registration Statement; and |
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the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Gennari Aronson, LLP, by calling Neil H. Aronson at (781) 719-9803, or, in his absence, Joseph B. Ramadei at (781) 719-9813. Thank you for your continued assistance.
Securities and Exchange Commission
February 9, 2018
Page 2
Sincerely yours,
/s/ Alex B. Rozek
Alex B. Rozek
Co-Chief Executive Officer
| cc: | Neil H. Aronson, Esq., Gennari Aronson, LLP |
| Joseph B. Ramadei, Esq., Gennari Aronson, LLP | |
| Christopher T. Jensen, Esq., Morgan, Lewis & Bockius LLP |