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SEC Company Response from LIONBRIDGE TECHNOLOGIES — Dec 12, 2005

LIONBRIDGE TECHNOLOGIES INC /DE/ (CIK 0001058299)
Date: Dec. 12, 2005 · CIK: 0001058299 · Accession: 0000950135-05-006925

AI Filing Summary & Sentiment

File numbers found in text: 333-129933

Date
December 12, 2005
Author
Not clearly detected
Form
CORRESP
Company
LIONBRIDGE TECHNOLOGIES INC /DE/ (CIK 0001058299)

Letter

corresp1

LIONBRIDGE TECHNOLOGIES, INC.

1050 WINTER STREET

WALTHAM, MASSACHUSETTS 02109

December 12, 2005

Via Facsimile — (202) 942-9585

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C. 20549-3561

Attention: Karen J. Garnett

RE:

Lionbridge Technologies, Inc.

Registration Statement on Form S-3, as amended

File No. 333-129933

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Lionbridge Technologies, Inc. (“Lionbridge”) hereby respectfully requests that the effectiveness of the above-referenced registration statement on Form S-3 be accelerated to 3:00 p.m. Eastern Standard Time on December 13, 2005, or as soon as practicable thereafter.

Lionbridge hereby acknowledges the following:

•

Should the Securities and Exchange Commission (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 Lionbridge from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

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

If you should have any questions regarding this request, please do not hesitate to contact me at (781) 434-6000 or Kenneth Gordon at (617) 570-1327 of Goodwin Procter LLP.

Very truly yours,
LIONBRIDGE TECHNOLOGIES, INC.

Show Raw Text
CORRESP
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corresp1

LIONBRIDGE TECHNOLOGIES, INC.

1050 WINTER STREET

WALTHAM, MASSACHUSETTS 02109

December 12, 2005

Via Facsimile — (202) 942-9585

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C. 20549-3561

Attention: Karen J. Garnett

    RE:

    Lionbridge Technologies, Inc.

Registration Statement on Form S-3, as amended

File No. 333-129933

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Lionbridge
Technologies, Inc. (“Lionbridge”) hereby respectfully requests that the effectiveness of the
above-referenced registration statement on Form S-3 be accelerated to 3:00 p.m. Eastern Standard
Time on December 13, 2005, or as soon as practicable thereafter.

Lionbridge hereby acknowledges the following:

    •

    Should the Securities and Exchange Commission (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 Lionbridge from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

    •

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

If you should have any questions regarding this request, please do not hesitate to contact me at
(781) 434-6000 or Kenneth Gordon at (617) 570-1327 of Goodwin Procter LLP.

Very truly yours,

LIONBRIDGE TECHNOLOGIES, INC.

    By:

    /s/ Margaret A. Shukur

    Name:

    Margaret A. Shukur

    Title:

    Secretary and General Counsel

    cc:

    Charito A. Mittelman, Esq., Securities and Exchange Commission

Kenneth Gordon, Esq., Goodwin Procter  LLP