SEC Comment Letter for BENTLEY SYSTEMS INC (BSY) (CIK 0001031308) (BSY) — Oct 26, 2020

BENTLEY SYSTEMS INC (BSY) (CIK 0001031308)
Date: Oct. 26, 2020 · CIK: 0001031308 · Accession: 0000000000-20-010108

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AI Filing Summary & Sentiment

Date

October 26, 2020

Author

Office of Technology

Form

UPLOAD

Company

BENTLEY SYSTEMS INC (BSY) (CIK 0001031308)

Letter

United States securities and exchange commission logo October 26, 2020 Gregory S. Bentley Chief Executive Officer Bentley Systems, Incorporated 685 Stockton Drive Exton, PA 19341 Re:Bentley Systems, Incorporated Draft Registration Statement on Form S-1 Submitted October 23, 2020 CIK No. 0001031308 Dear Mr. Bentley: This is to advise you that we do not intend to review your registration statement. We request that you publicly file your registration statement no later than 48 hours prior to the requested effective date and time. Please refer to Rule 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you require further assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815. Sincerely, Division of Corporation Finance Office of Technology cc: Richard Fenyes, Esq.

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United States securities and exchange commission logo
October 26, 2020
Gregory S. Bentley
Chief Executive Officer
Bentley Systems, Incorporated
685 Stockton Drive
Exton, PA 19341
Re:Bentley Systems, Incorporated
Draft Registration Statement on Form S-1
Submitted October 23, 2020
CIK No. 0001031308
Dear Mr. Bentley:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours prior
to the requested effective date and time. Please refer to Rule 461 regarding requests for
acceleration. We remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453, with any questions.  If you require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Richard Fenyes, Esq.

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