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SEC Company Response from BUSINESS OBJECTS S.A. (CIK 0000928753) — Oct 24, 2005

BUSINESS OBJECTS S.A. (CIK 0000928753)
Date: Oct. 24, 2005 · CIK: 0000928753 · Accession: 0000891618-05-000802

AI Filing Summary & Sentiment

File numbers found in text: 333-119662

Referenced dates: November 4, 2004

Date
October 24, 2005
Author
BUSINESS OBJECTS S.A.
Form
CORRESP
Company
BUSINESS OBJECTS S.A. (CIK 0000928753)

Letter

Securities and Exchange Commission Attn: Sara Kalin, Esq. Business Objects S.A. Registration Statement on Form S-3, as amended (File No. 333-119662)

Re:

Dear Ms. Kalin:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Business Objects S.A., a société anonyme organized under the laws of the French Republic (the “Registrant”), hereby requests that the effectiveness of the above captioned Registration Statement on Form S-3 (the “Registration Statement”) be accelerated so that such Registration Statement becomes effective at 5:00 p.m. EST, on Wednesday, October 26, 2005, or as soon thereafter as practicable.

In response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated November 4, 2004 relating to the Registration Statement, the Registrant hereby acknowledges the following:

•

should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please advise the undersigned and the persons indicated on the cover of the Registration Statement when the order permitting such Registration Statement to become effective is issued.

Sincerely,
BUSINESS OBJECTS S.A.

Show Raw Text
CORRESP
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filename1.htm

corresp

[LETTERHEAD OF BUSINESS OBJECTS]

Monday October 24, 2005

VIA FACSIMILE (202-942-9544) AND EDGAR

Securities
and Exchange Commission

450 Fifth Street, NW

Washington, DC 20549-0306

Attn: Sara Kalin, Esq.

    Re:

    Business Objects S.A.

Registration Statement on Form S-3, as amended (File No. 333-119662)

Dear Ms. Kalin:

     Pursuant to Rule 461 of the Securities Act of 1933, as amended, Business
Objects S.A., a société anonyme organized under the laws of the French Republic
(the “Registrant”), hereby requests that the effectiveness of the above
captioned Registration Statement on Form S-3 (the “Registration Statement”) be
accelerated so that such Registration Statement becomes effective at
5:00 p.m. EST, on Wednesday, October 26, 2005, or as soon thereafter as practicable.

     In response to comments from the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) received by letter dated November 4,
2004 relating to the Registration Statement, the Registrant hereby acknowledges
the following:

    •

    should the Commission or the Staff, acting pursuant to
delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the
filing;

    •

    the action of the Commission or the Staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Registrant from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and

    •

    the Registrant may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

     Please advise the undersigned and the persons indicated on the cover of
the Registration Statement when the order permitting such Registration
Statement to become effective is issued.

    Sincerely,

BUSINESS OBJECTS S.A.

    /s/ James R. Tolonen

    James R. Tolonen

    Chief Financial Officer