SEC Company Response from BOTTOMLINE TECHNOLOGIES — Nov 1, 2005
BOTTOMLINE TECHNOLOGIES INC /DE/ (CIK 0001073349)
Date: Nov. 1, 2005 · CIK: 0001073349 · Accession: 0001193125-05-213196
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File numbers found in text: 333-128295
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CORRESP 1 filename1.htm ACCELERATION REQUEST Bottomline Technologies (de), Inc. 325 Corporate Drive Portsmouth, New Hampshire 03801 November 1, 2005 VIA EDGAR and Facsimile Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Maryse Mills-Apenteng Re: Bottomline Technologies (de), Inc. Registration Statement on Form S-3 File No. 333-128295 Request for Acceleration Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Bottomline Technologies (de), Inc. (the “Registrant”) hereby requests acceleration of the effective date of its Registration Statement on Form S-3, as amended (File No. 333-128295) (the “Registration Statement”), so that it may become effective at 5:00 pm on November 3, 2005, or as soon thereafter as practicable. The Registrant hereby acknowledges that: (i) should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; (ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and (iii) the Registrant may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Securities and Exchange Commission November 1, 2005 Page 2 Very truly yours, BOTTOMLINE TECHNOLOGIES (DE), INC. By: /s/ Kevin M. Donovan Name: Kevin M. Donovan Title: Chief Financial Officer and Treasurer