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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

Date
November 10, 2020
Author
Goldman Sachs & Co. LLC
Form
CORRESP
Company
BENTLEY SYSTEMS INC (BSY) (CIK 0001031308)

Letter

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,

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

Show Raw Text
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