United States securities and exchange commission logo
February 2, 2024
Charles Young
Chief Executive Officer
Smart Sand, Inc.
28420 Hardy Toll Road, Suite 130
Spring, Texas 77373
Re: Smart Sand, Inc.
Registration
Statement on Form S-3
Filed January 17,
2024
File No. 333-276549
Dear Charles Young:
We have conducted a limited review of your registration statement
and have the
following comment.
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe a comment applies to your
facts and circumstances
or do not believe an amendment is appropriate, please tell us why in
your response.
After reviewing any amendment to your registration statement and
the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form S-3
General
1. We note that you
incorporate by reference your Form 10-K for the fiscal year ended
December 31, 2022.
Please be advised that we will not be in a position to declare this
registration statement
effective until you have resolved all comments on your Exchange
Act reports.
Charles Young
Smart Sand, Inc.
February 2, 2024
Page 2
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Please contact Claudia Rios at 202-551-8770 or Daniel Morris at
202-551-3314 with any
other questions.
Sincerely,
FirstName LastNameCharles Young
Division of
Corporation Finance
Comapany NameSmart Sand, Inc.
Office of Energy &
Transportation
February 2, 2024 Page 2
cc: Ryan J. Maierson, Esq.
FirstName LastName