SEC Company Response from SABA SOFTWARE INC (CIK 0001070380) — Oct 3, 2005
SABA SOFTWARE INC (CIK 0001070380)
Date: Oct. 3, 2005 · CIK: 0001070380 · Accession: 0001193125-05-195508
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File numbers found in text: 333-125778
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CORRESP 1 filename1.htm Acceleration Request SABA SOFTWARE, INC. 2400 Bridge Parkway Redwood Shores, California 94065 October 3, 2005 VIA FAX AND EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: Saba Software, Inc. Registration Statement on Form S-3 (No. 333-125778) Ladies and Gentlemen: Saba Software, Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced registration statement to become effective at 1:00 p.m. (EDT) on Wednesday, October 5, 2005 or as soon thereafter as is practicable. In connection with this request, the Company hereby acknowledges that: • should the Commission or the staff, acting pursuant to delegated authority, declare the above-referenced registration statement effective, it does not foreclose the Commission from taking any action with respect to the registration statement; • the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the registration statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the registration statement; and • the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Very truly yours, SABA SOFTWARE, INC. By: /s/ Peter E. Williams, III Peter E. Williams, III Chief Financial Officer