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                                                              February 11, 2021
Via E-mail

J. Abbott R. Cooper
Managing Member
Driver Management Company LLC
250 Park Avenue, 7th Floor
New York, NY 10177

       Re:     First United Corporation
               Preliminary Proxy Statement on Schedule 14A
               Filed February 2, 2021 by Driver Management Company LLC, Driver
                       Opportunity Partners I LP, and J. Abbott R. Cooper
               Soliciting Materials Filed Pursuant to Rule 14a-12
               Filed February 4, 2021
               File No. 000-14237

Dear Mr. Cooper:

        The staff in the Office of Mergers and Acquisitions has reviewed the
above-captioned
filings. We have the comments set forth below.

       Please respond to this letter by amending the referenced filings and/or
by providing the
requested information. After reviewing any amendment to the filings and any
information
provided in response to these comments, we may have additional comments.

       If you do not believe our comments apply to your facts and
circumstances, and/or do not
believe an amendment is appropriate, please tell us why in a written response.

Preliminary Proxy Statement on Schedule 14A
General

1. Please ensure that your revised preliminary proxy statement includes page
numbers
   throughout. Refer to Exchange Act Rule 0-3(b).

2. Please ensure your revised preliminary proxy statement is filed using the
correct EDGAR tag
   of PRRN14A to indicate a filing by non-management. Filers must prepare
electronic filings
   in the manner prescribed by the EDGAR Filer Manual. Refer to Rule 232.301 of
Regulation
   S-T.

3. Please advise us as to when the participants anticipate distributing the
proxy statement.
   Given that reliance on Rule 14a-5(c) is impermissible at any time before the
registrant
   distributes its proxy statement, the participants will accept all legal risk
in connection with
 J. Abbott R. Cooper
Driver Management Company LLC
February 11, 2021
Page 2

   distributing the initial definitive proxy statement without all required
disclosures and should
   undertake to subsequently provide any omitted information in a supplement in
order to
   mitigate that risk.

4. Revise to clearly mark your preliminary proxy statement and the form of
proxy as
      preliminary copies.    Refer to Rule 14a-6(e)(1).

5. Refer to the soliciting material filed by the Company pursuant to Rule
14a-12 on January 12,
   2021. Given the Company   s disclosed intentions to ask shareholders to
approve a proposal
   to declassify the board, please revise your statement that the participants
are not aware of any
   other matters to be brought before the annual meeting.

Proposal No. 1, Election of Directors, page 2

6. We note that you intend to include certain of the Company  s nominees on
your proxy card
   and name those nominees in your proxy statement. Please advise us as to how
you plan to
   comply with the requirements set forth in Rule 14a-4(d)(4). Note that you
must seek
   authority to vote in the aggregate for the number of director positions
subject to election, and
   represent in the proxy statement and proxy card that you will vote for all
of the Company   s
   nominees other than the Company nominees you specify.

7. Revise to disclose the basis for the statement that your nominee is
independent of the
   Company. In this respect, given that Driver Management has a pending lawsuit
naming the
   Company as a defendant, please address the possibility, if true, that such
litigation could
   result in a determination that your nominee does not satisfy the
independence requirements
   under the applicable exchange listing rule.

Proposal No. 3, Majority Vote Proposal, page 5

8. Please revise to clarify, if true, that shareholder approval of this
proposal would result in
   amendments to the Company   s charter, bylaws or other governance documents.
Similarly,
   disclose the general effect of any such amendment. Refer to Item 19 of
Schedule 14A.
   Please also consider this comment applicable to the Independent Chair
Proposal and the
   Shareholder Bylaw Amendment Proposal.

Proposal No. 4, Beneficial Ownership Proposal, page 5

9. With a view toward revised disclosure, please advise us of how Driver
determined that it
   does not have any material interest in the proposal other than the interest
common to all
   shareholders. Please address the ongoing litigation between Driver and the
Company. In
   your response letter, please also address the similar determination made
with respect to the
   No Disenfranchisement Proposal.
 J. Abbott R. Cooper
Driver Management Company LLC
February 11, 2021
Page 3

Proposal No. 5, No Disenfranchisement Proposal, page 6

10. Please provide us with the factual foundation in support of the following
assertions. See
    Rule 14a-9.

                The Company has previously lobbied the Maryland Commissioner on
Financial
           Regulation to investigate Driver for violations of Section 3-314 for
the express
           purpose of disenfranchising Driver.

                Driver does not believe that the Company has   any affirmative
obligation to report
           potential violations of Section 3-314 to the Maryland Commissioner
of Financial
           Regulation.

Additional Participant Information, page 14

11. Correct your disclosure of the participants    beneficial ownership in the
penultimate
    paragraph on page 14, which appears to contain a typographical error.

Letter to Shareholders

12. The table containing the participants    proposals includes eight
proposals. Elsewhere in the
    proxy statement, reference is made to eleven proposals. Please revise to
rectify the
    inconsistency.

Form of Proxy

13. The first page of the form of proxy states that if no direction is
indicated with respect to the
    proposals, the proxy will be voted    against    proposals 2 and 3, which
conflicts with both
    disclosure in your preliminary proxy statement and other references on the
proxy card.
    Similarly, the second page of the form of proxy states    Driver strongly
recommends that
    shareholders vote   against proposals 8 and 9.    Revise to correct this
conflicting
    information.

DFAN filed February 4, 2021

14. Each statement or assertion of opinion or belief must be clearly
characterized as such, and a
    reasonable factual basis must exist for each such opinion or belief.
Support for opinions or
    beliefs should be self-evident, disclosed in the proxy statement or
provided to the staff on a
    supplemental basis. In future soliciting materials, refrain from statements
implying the
    Company is taking away shareholder voting rights, absent sufficient factual
support.

15. Please provide us with the factual foundation in support of the following
assertion:       the
    company had been engaged in a secret campaign to prevent shareholders from
having a
 J. Abbott R. Cooper
Driver Management Company LLC
February 11, 2021
Page 4

   choice in deciding directors (through a contested election) and then
repeatedly lied about the
   existence of that campaign.    See Rule 14a-9.

                                              * * *
        We remind you that the participants are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

       Please direct any questions to me at (202) 551-7951.


                                                            Sincerely,

                                                            /s/ Joshua Shainess

                                                            Joshua Shainess
                                                            Special Counsel
                                                            Office of Mergers
and Acquisitions
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