SEC Company Response from MERCADOLIBRE INC (MELI) (CIK 0001099590) (MELI) — Aug 7, 2007
MERCADOLIBRE INC (MELI) (CIK 0001099590)
Date: Aug. 7, 2007 · CIK: 0001099590 · Accession: 0001193125-07-173580
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-142880
Letter
VIA EDGAR AND FACSIMILE United States Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549-7010 Re: MercadoLibre, Inc. Registration Statement on Form S-1 File No. 333-142880
Dear Ms. LaMothe:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, MercadoLibre, Inc. (the “Company”) hereby requests acceleration of effectiveness of the above-captioned Registration Statement to 1:00 p.m. Eastern time on August 9, 2007, or as soon thereafter as practicable.
In connection with this request for effectiveness, the Company acknowledges the following:
(i) should 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;
(ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
(iii) the Company may not assert this action 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,
MERCADOLIBRE, INC.
By:
/s/ Marcos Galperin
Name: Marcos Galperin
Title: President and Chief Executive Officer
cc: S. Todd Crider, Esq.
Edward W. Elmore, Jr., Esq.
John F. Haley, Esq.
Nicolás Szekasy
Rachel Zablow
J.P. MORGAN SECURITIES INC.
MERRILL LYNCH, PIERCE, FENNER
277 Park Avenue
& SMITH INCORPORATED
New York, New York 10172
4 World Financial Center
New York, New York 10080
August 7, 2007
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Re:
MercadoLibre, Inc. (the “Company”)
Common Stock
Registration Statement on Form S-1 (File No. 333-142880)
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby join in the request of the Company that the effective date of the Registration Statement be accelerated so that the Registration Statement may become effective by 1:00 p.m. (New York City time) on August 9, 2007 or as soon thereafter as practicable.
The following information with respect to the distribution of the preliminary prospectus dated July 27, 2007 (the “Preliminary Prospectus”) is furnished pursuant to Rule 460 of the Rules and Regulations of the Commission under the Securities Act of 1933, as amended, in connection with the request for acceleration of the effective date of the Registration Statement.
The number of Preliminary Prospectuses distributed between July 27, 2007 and August 7, 2007 is as follows:
No. of Preliminary Prospectuses
To Prospective Underwriters
8,420
To Institutions and Individuals
4,551
To Others
Total
13,081
Very truly yours,
J.P. MORGAN SECURITIES INC.
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CORRESP 1 filename1.htm Accereration Request August 7, 2007 VIA EDGAR AND FACSIMILE Ms. Cicely LaMothe Accounting Branch Chief United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-7010 Re: MercadoLibre, Inc. Registration Statement on Form S-1 File No. 333-142880 Dear Ms. LaMothe: Pursuant to Rule 461 under the Securities Act of 1933, as amended, MercadoLibre, Inc. (the “Company”) hereby requests acceleration of effectiveness of the above-captioned Registration Statement to 1:00 p.m. Eastern time on August 9, 2007, or as soon thereafter as practicable. In connection with this request for effectiveness, the Company acknowledges the following: (i) should 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; (ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert this action 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, MERCADOLIBRE, INC. By: /s/ Marcos Galperin Name: Marcos Galperin Title: President and Chief Executive Officer cc: S. Todd Crider, Esq. Edward W. Elmore, Jr., Esq. John F. Haley, Esq. Nicolás Szekasy Rachel Zablow J.P. MORGAN SECURITIES INC. MERRILL LYNCH, PIERCE, FENNER 277 Park Avenue & SMITH INCORPORATED New York, New York 10172 4 World Financial Center New York, New York 10080 August 7, 2007 Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549 Re: MercadoLibre, Inc. (the “Company”) Common Stock Registration Statement on Form S-1 (File No. 333-142880) Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby join in the request of the Company that the effective date of the Registration Statement be accelerated so that the Registration Statement may become effective by 1:00 p.m. (New York City time) on August 9, 2007 or as soon thereafter as practicable. The following information with respect to the distribution of the preliminary prospectus dated July 27, 2007 (the “Preliminary Prospectus”) is furnished pursuant to Rule 460 of the Rules and Regulations of the Commission under the Securities Act of 1933, as amended, in connection with the request for acceleration of the effective date of the Registration Statement. The number of Preliminary Prospectuses distributed between July 27, 2007 and August 7, 2007 is as follows: No. of Preliminary Prospectuses To Prospective Underwriters 8,420 To Institutions and Individuals 4,551 To Others 110 Total 13,081 Very truly yours, J.P. MORGAN SECURITIES INC. For itself and on behalf of the several Underwriters listed in the Underwriting Agreement. By /s/ Daniel Darahem Daniel Darahem Authorized Signatory MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED For itself and on behalf of the several Underwriters listed in the Underwriting Agreement. By /s/ Daniel Gonzalez Daniel Gonzalez Authorized Signatory