SEC Company Response from BENTLEY SYSTEMS INC (BSY) (CIK 0001031308) (BSY) — Nov 10, 2020
BENTLEY SYSTEMS INC (BSY) (CIK 0001031308)
Date: Nov. 10, 2020 · CIK: 0001031308 · Accession: 0001104659-20-123659
AI Filing Summary & Sentiment
File numbers found in text: 333-250002
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CORRESP
1
filename1.htm
November 10, 2020
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Jan
Woo, Legal Branch Chief
Jeffrey Kauten, Staff Attorney
Kathleen Collins, Accounting Branch Chief
David Edgar, Staff Accountant
RE: Bentley Systems, Incorporated
Registration Statement on Form S-1
File No. 333-250002
Acceleration Request
Requested Date: November 12,
2020
Requested Time: 4:00 PM, Eastern
Time
Ladies and Gentlemen:
In accordance with Rule 461 under the
Securities Act of 1933, as amended (the “Act”), Goldman Sachs & Co. LLC and BofA Securities, Inc.,
as representatives of the several underwriters, hereby joins Bentley Systems, Incorporated in requesting that the U.S. Securities
and Exchange Commission (the “Commission”) take appropriate action to cause the Registration Statement
on Form S-1 (File No. 333-250002) (the “Registration Statement”) to become effective on November 12,
2020, at 4:00 PM, Eastern Time, or as soon as practicable thereafter.
Pursuant to Rule 460 under the Act,
please be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to underwriters,
dealers, institutions and others, prior to the requested effective time of the Registration Statement.
We, as representative of the several underwriters,
have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply,
with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, to the extent applicable.
[Signature Page Follows]
Very truly yours,
Goldman Sachs & Co. LLC
By:
/s/ William Connolly
Name:
William Connolly
Title:
Managing Director
BofA Securities, Inc.
By:
/s/ Michael Liloia
Name:
Michael Liloia
Title:
Director
cc: David J. Hollister, Bentley Systems, Incorporated
David R. Shaman, Bentley Systems, Incorporated
Richard A. Fenyes, Simpson Thacher & Bartlett
LLP
Jonathan R. Ozner, Simpson Thacher & Bartlett
LLP
Kenneth J. Gordon, Goodwin Procter LLP
Erica D. Kassman, Goodwin Procter LLP
Signature Page to Acceleration
Request