Giovanni Caruso



345 Park Avenue
New York, NY 10154

Direct     212.407.4866

Main       212.407.4000

Fax          212.937.3943


Via Edgar


March 14, 2018


H. Roger Schwall

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549


Re:Trident Acquisitions Corp.
Draft Registration Statement on Form S-1
Submitted March 6, 2017
CIK No. 0001673481


Dear Mr. Schwall:


On behalf of our client, Trident Acquisitions Corp. (the “Company”), we hereby provide a response to the comments issued in a letter dated April 3, 2017 (the “Staff’s Letter”) regarding the Company’s draft Registration Statement on Form S-1 (the “Registration Statement”). Contemporaneously, we are filing the amended Registration Statement via Edgar (the “Amended S-1”).


In order to facilitate the review by the Commission’s staff (the “Staff”) of the Amended S-1, we have responded, on behalf of the Company, to the comments set forth in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff’s comments and correspond to the numbered paragraph in the Staff’s Letter.


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A limited liability partnership including professional corporations





H. Roger Schwall

March 14, 2018

Page 2


Our Investment Strategy, page 53


1.Please provide us with precise, independent support for the assertions regarding the 1.valuation disparities which appear in the first paragraph of this section. Include the specific portions upon which you rely; if you do not have independent support for a statement, please either revise the language to make clear the basis for the statement or delete it. We refer you to prior comment 1.


Response: The Company has deleted the language relating to the valuation disparities in response to the Staff’s comments.


Financial Statements

Statement of Cash Flows, page F-6


2.Please revise your statement of cash flows to present cash disbursements for deferred offering costs as a financing activity, or explain why you believe its current classification as an operating activity is appropriate.


Response: The Statements of Cash Flows has been revised in accordance with the Staff’s comments.


Please call me at 212 407-4866 if you would like additional information with respect to any of the foregoing. Thank you.


/s/ Giovanni Caruso  
Giovanni Caruso