SEC Company Response from VALUECLICK — Sep 20, 2005
VALUECLICK INC/CA (CIK 0001080034)
Date: Sept. 20, 2005 · CIK: 0001080034 · Accession: 0001047469-05-023182
AI Filing Summary & Sentiment
File numbers found in text: 333-127804
Letter
[LETTERHEAD OF VALUECLICK, INC.]
September 20,
VIA EDGAR AND FEDERAL EXPRESS
(202) 772-9205
U.S. Securities and Exchange Commission
Office of Mergers and Acquisitions
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549-3628
Attention: Daniel Zimmerman
Re:ValueClick, Inc.
Registration Statement on Form S-4 (Registration No. 333-127804)
Ladies and Gentlemen:
In connection with the registration of up to 17,386,493 shares of common stock of ValueClick, Inc. (the "Company") pursuant to the above-referenced Registration Statement, the Company respectfully requests the acceleration of the effectiveness of such Registration Statement to Thursday, September 22, 2005, at 4:30 p.m. eastern standard time, or as soon thereafter as possible.
As requested by the U.S. Securities and Exchange Commission, the Company hereby confirms the following:
(1)the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
(2)staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and
(3)the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Sincerely,
ValueClick, Inc.
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[LETTERHEAD OF VALUECLICK, INC.]
September 20,
2005
VIA
EDGAR AND FEDERAL EXPRESS
(202) 772-9205
U.S.
Securities and Exchange Commission
Office of Mergers and Acquisitions
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549-3628
Attention: Daniel Zimmerman
Re:ValueClick, Inc.
Registration Statement on Form S-4 (Registration No. 333-127804)
Ladies
and Gentlemen:
In
connection with the registration of up to 17,386,493 shares of common stock of ValueClick, Inc. (the "Company") pursuant to the above-referenced Registration Statement, the
Company respectfully requests the acceleration of the effectiveness of such Registration Statement to Thursday, September 22, 2005, at 4:30 p.m. eastern standard time, or as soon
thereafter as possible.
As
requested by the U.S. Securities and Exchange Commission, the Company hereby confirms the following:
(1)the
Company is responsible for the adequacy and accuracy of the disclosure in the filings;
(2)staff
comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and
(3)the
Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Sincerely,
ValueClick, Inc.
By:
/s/ SCOTT BARLOW Scott Barlow, General Counsel