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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

AI Filing Summary & Sentiment

File numbers found in text: 333-125778

Date
October 3, 2005
Author
Not clearly detected
Form
CORRESP
Company
SABA SOFTWARE INC (CIK 0001070380)

Letter

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.

Show Raw Text
CORRESP
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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