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SEC Company Response from TRINET GROUP, INC. (TNET) (CIK 0000937098) (TNET) — Jul 21, 2017

TRINET GROUP, INC. (TNET) (CIK 0000937098)
Date: July 21, 2017 · CIK: 0000937098 · Accession: 0000950103-17-006962

Financial Reporting Internal Controls Regulatory Compliance

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Referenced dates: July 18, 2017

Date
July 21, 2017
Author
Sarah K. Solum
Form
CORRESP
Company
TRINET GROUP, INC. (TNET) (CIK 0000937098)

Letter

VIA EDGAR Division of Corporation Finance Attention: William H. Thompson Office of Consumer Products Yolanda Guobadia Staff Accountant Re: Letter dated July 18, 2017 to TriNet Group, Inc. (“TriNet”) regarding TriNet’s Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 28, 2017 (File No. 1-36373)

Dear Ms. Guobadia and Mr. Thompson:

On behalf of TriNet Group, Inc., thank you for your letter dated July 18, 2017 regarding TriNet’s Form 10-K for the most recently completed fiscal year. TriNet is currently in the midst of preparing its Form 10-Q for the six months ended June 30, 2017, which it anticipates filing on or about August 2, 2017, and will be holding its annual sales conference shortly after the Form 10-Q filing. In addition, as previously disclosed, TriNet has recently undergone a change in its principal financial and principal accounting officers. Accordingly, TriNet very much appreciates the Staff’s willingness to allow TriNet time to carefully consider and respond to each comment in the letter. This letter is to confirm, on behalf of TriNet, our conversation today that TriNet will respond to your letter no later than August 18, 2017. Please feel free to contact me at (650) 752-2011 with any questions.

July 21, 2017

Very truly yours,
/s/
Sarah K. Solum

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CORRESP
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    New York

Northern California

Washington DC

São Paulo

London

    Paris

Madrid

Tokyo

Beijing

Hong Kong

        Sarah K. Solum

    Davis Polk & Wardwell LLP

1600 El Camino Real

Menlo Park, CA 94025
    650 752 2011 tel

650 752 3611 fax

sarah.solum@davispolk.com

    July 21, 2017

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    William H. Thompson

    Accounting Branch Chief

    Office of Consumer Products

    Yolanda Guobadia

    Staff Accountant

 Re: Letter dated July 18, 2017 to TriNet Group, Inc. (“TriNet”) regarding TriNet’s Form 10-K for Fiscal Year
Ended December 31, 2016 Filed February 28, 2017 (File No. 1-36373)

Dear Ms. Guobadia and Mr. Thompson:

On behalf of TriNet Group, Inc., thank
you for your letter dated July 18, 2017 regarding TriNet’s Form 10-K for the most recently completed fiscal year. TriNet
is currently in the midst of preparing its Form 10-Q for the six months ended June 30, 2017, which it anticipates filing on or
about August 2, 2017, and will be holding its annual sales conference shortly after the Form 10-Q filing. In addition, as previously
disclosed, TriNet has recently undergone a change in its principal financial and principal accounting officers. Accordingly, TriNet
very much appreciates the Staff’s willingness to allow TriNet time to carefully consider and respond to each comment in the
letter. This letter is to confirm, on behalf of TriNet, our conversation today that TriNet will respond to your letter no later
than August 18, 2017. Please feel free to contact me at (650) 752-2011 with any questions.

    2
    July
    21, 2017

    Very truly yours,

    /s/
    Sarah K. Solum

    Sarah
    K. Solum

    cc:
    Burton M. Goldfield, Chief Executive Officer

    Richard Beckert, Chief Financial Officer

    Michael Murphy, Chief Accounting Officer

    Brady Mickelsen, Chief Legal Officer

    (TriNet Group, Inc.)