UDRUDR, Inc.

Please expand your discussion to address how the experience of the Lead Independent Director is brought to bear in connection with your board’s role in risk oversight.

to the Staff’s comment, beginning with the proxy statement for the 2023 Annual Meeting of Shareholders, the Company will expand the above-referenced disclosure in the Proxy Statement to address how the extensive experience of the Board’s Lead Independent Director is brought to bear in connection with the Board’s role in risk oversight. Read in the reply ↗

Please expand upon the role that your Lead Independent Director plays in the leadership of the board. For example, please enhance your disclosure to address whether or not your Lead Independent Director may: • represent the board in communications with shareholders and other stakeholders; or • require board consideration of, and/or override your CEO on, any risk matters.

to the Staff’s comment, beginning with the proxy statement for the 2023 Annual Meeting of Shareholders, the Company will expand the above-referenced discussion in the Proxy Statement addressing the role that the Lead Independent Director plays in the leadership of the Board. To the extent applicable, the Company will address the examples cited by the Staff in Comment 2. Read in the reply ↗

Please expand upon how your board administers its risk oversight function. For example, please disclose: • the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or long-term) and how you apply different oversight standards based upon the immediacy of the risk assessed; • whether you consult with outside advisors and experts to anticipate future threats and trends, and how often you

Rest of the question

re-assess your risk environment; • how the board interacts with management to address existing risks and identify significant emerging risks; • whether you have a Chief Compliance Officer and to whom this position reports; and • how your risk oversight process aligns with your disclosure controls and procedures.

to the Staff’s comment, beginning with the proxy statement for the 2023 Annual Meeting of Shareholders, the Company will expand the above-referenced discussion in the Proxy Statement addressing how the Board administers its risk oversight function. To the extent applicable, the Company will address the examples cited by the Staff in Comment 3. Read in the reply ↗