SEC Comment Letter for BUSINESS OBJECTS S.A. (CIK 0000928753) — Jul 6, 2005
BUSINESS OBJECTS S.A. (CIK 0000928753)
Date: July 6, 2005 · CIK: 0000928753 · Accession: 0000000000-05-034270
AI Filing Summary & Sentiment
File numbers found in text: 333-119662, 333-126082
Letter
July 6, 2005 Mail Stop 4561 Ms. Susan J. Wolfe, Esq. Senior Vice President, General Counsel and Secretary c/o Business Objects America 3030 Orchard Parkway San Jose, CA 95134
Re: Business Objects S.A. Amendment No. 2 to Registration Statement on Form S-3 File No. 333-119662
Dear Ms. Wolfe:
In connection with our limited review of your filing, we have reviewed your second amendment and have the following additional comments.
Prospectus Cover Page 1. We note that you filed an additional Form S-3 (333-126082) on June 23, 2005. Please revise the cover page to disclose the existence of this separate offering and to indicate the number of shares covered by the other registration statement. Additionally, please note that comments regarding registration statement number 333-126082 will be sent under separate cover. Legal Opinion
2. Please file a revised legal opinion updated to refer to the increased number of shares being offered under the registration statement.
** ** ** ** ** **
As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
We direct your attention to Rule 461 regarding requesting acceleration of a registration statement. Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration. Please provide this request at least two business days in advance of the requested effective date.
If you have any questions, please call Sara Kalin at (202) 551- 3454. If you require further assistance, you may call me at (202) 551-3730.
Sincerely,
Mark P. Shuman
Branch Chief-Legal
Show Raw Text
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<TYPE>LETTER
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<TEXT>
July 6, 2005
Mail Stop 4561
Ms. Susan J. Wolfe, Esq.
Senior Vice President, General Counsel and Secretary
c/o Business Objects America
3030 Orchard Parkway
San Jose, CA 95134
Re: Business Objects S.A.
Amendment No. 2 to Registration Statement on Form S-3
File No. 333-119662
Dear Ms. Wolfe:
In connection with our limited review of your filing, we have
reviewed your second amendment and have the following additional
comments.
Prospectus Cover Page
1. We note that you filed an additional Form S-3 (333-126082) on
June
23, 2005. Please revise the cover page to disclose the existence
of
this separate offering and to indicate the number of shares
covered
by the other registration statement. Additionally, please note
that
comments regarding registration statement number 333-126082 will
be
sent under separate cover.
Legal Opinion
2. Please file a revised legal opinion updated to refer to the
increased number of shares being offered under the registration
statement.
** ** ** ** ** **
As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with
marked
copies of the amendment to expedite our review. Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review. Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.
We direct your attention to Rule 461 regarding requesting
acceleration of a registration statement. Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration. Please provide this
request
at least two business days in advance of the requested effective
date.
If you have any questions, please call Sara Kalin at (202)
551-
3454. If you require further assistance, you may call me at (202)
551-3730.
Sincerely,
Mark P. Shuman
Branch Chief-Legal
cc: Via Facsimile
John T. Sheridan, Esq.
Julia Reigel, Esq.
Michael Post, Esq.
Wilson Sonsini Goodrich & Rosati
Professional Corporation
650 Page Mill Road
Palo Alto, CA 94304
Telephone: (650) 493-9300
Facsimile: (650) 493-6811
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Ms. Susan Wolfe
Business Objects S.A.
July 6, 2005
Page 1
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