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                                                             June 16, 2025

Brian Finn
Chief Investment Officer
Findell Capital Management LLC
88 Pine Street, 22nd Fl.
New York, NY 10005

       Re: Findell Capital Management LLC
           Oportun Financial Corporation
           Additional Soliciting Material filed June 3 and 5, 2025, by Findell
Capital
           Management LLC et al.
           File No. 001-39050
Dear Brian Finn:

       We have reviewed your filings and have the following comments. In some
of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

        Please respond to these comments by providing the requested information
or advise us
as soon as possible when you will respond. If you do not believe our comments
apply to your
facts and circumstances, please tell us why in your response.

       After reviewing your response to these comments, we may have additional
comments.

General

1.     The letter to shareholders issued on June 3, 2025, and filed as
additional soliciting
       material states that:

             "legacy directors who control the majority of the Board have no
lending
           experience and share close personal and professional ties with CEO
Raul
           Vazquez";
             "Mr. Vazquez has worked to destroy a great lending business";
              "the Board   s self-defeating and entrenching behavior has made
it clear to us that
           the main goal of the legacy directors is not delivering stockholder
value,
           but preventing industry experience and independence from having a
real voice in
           the boardroom";
             "management decisions would have bankrupted the Company without
Findell   s
 June 16, 2025
Page 2

             involvement"; and
               "[a]mong the legacy Board members, there are many overlapping
personal and
             professional relationships with each other and with CEO Vazquez
that raise
             serious questions about the ability of these directors to provide
appropriate
             oversight. For example, Mr. Vazquez is a board member of Intuit
and oversaw
             Mr. Williams and Ms. Lee in that capacity."

         Such statements appear to impugn the character, integrity and personal
reputation of
         Mr. Vazquez and the Board without adequate factual foundation. Please
do not use
         these or similar statements in soliciting materials without providing
a proper factual
         foundation for the statements. In addition, as to matters for which
the filing persons do
         have a proper factual foundation, please avoid making statements about
those matters
         that go beyond the scope of what is reasonably supported by the
factual foundation.
         Please note that characterizing a statement as one   s opinion or
belief does not
         eliminate the need to provide a proper factual foundation for the
statement; there must
         be a reasonable basis for each opinion or belief that the filing
persons express. Please
         refer to Note (b) to Rule 14a-9.
Additional Soliciting Material filed June 5, 2025
Item 1

2.       We note the following statements:

               "Ms. Lee and the Rest of the Legacy Directors Have Overseen
Massive Value
             Destruction and Lack Lending Experience, Making Them
Underqualified to Serve
             as Lead Independent Director";
               "the legacy directors [ ] collectively appear interested only in
entrenching
             themselves and ignoring the best interests of Oportun"; and
               "these legacy directors are unqualified to serve on this board,
let alone serve as
             lead independent director."

         Refer to our prior comment above. Please do not use these or similar
statements in
         your filings without providing a proper factual foundation. Please
refer to filing
         persons' obligations under Exchange Act Rule 14a-9.



        We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.
 June 16, 2025
Page 3

      Please direct any questions to Laura McKenzie at 202-551-4568 or Perry
Hindin at
202-551-3444 .



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Mergers &
Acquisitions
cc:   Andrew Freedman
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