SEC Company Response from Seagate Technology Holdings plc (STX) (CIK 0001137789) (STX) — Mar 7, 2005
Seagate Technology Holdings plc (STX) (CIK 0001137789)
Date: March 7, 2005 · CIK: 0001137789 · Accession: 0001193125-05-043924
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File numbers found in text: 333-122149
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CORRESP 1 filename1.htm Acceleration Request SEAGATE TECHNOLOGY 920 Disc Drive P.O. Box 66360 Scotts Valley, California 95067 VIA FACSIMILE AND EDGAR March 7, 2005 Re: Seagate Technology Registration Statement on Form S-3 (File. No. 333-122149) (the “Registration Statement”) Securities and Exchange Commission Division of Corporate Finance Washington, D.C. 20549-0405 Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Seagate Technology (the “Company”) hereby requests acceleration of the effectiveness of the above-referenced Registration Statement on Form S-3 so that it will become effective at 4:00 p.m. (Washington, D.C. time) on Wednesday, March 9, 2005, or as soon thereafter as is practicable. The Company hereby acknowledges that: · should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (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; · 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 this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We request that we be notified of such effectiveness by telephone call to Tom Wuchenich of Simpson Thacher & Bartlett LLP, at (310) 407-7505. Please provide copies of the Commission’s order declaring the Registration Statement effective to William L. Hudson, Executive Vice President, General Counsel and Secretary of Seagate Technology, 920 Disc Drive, P.O. Box 66360, Scotts Valley, California 95067, and to William H. Hinman, Jr. of Simpson Thacher & Bartlett LLP, 3330 Hillview Avenue, Palo Alto, California 94304. [Remainder of this page intentionally left blank] Very truly yours, SEAGATE TECHNOLOGY By: /s/ WILLIAM L. HUDSON Name: William L. Hudson Title: Executive Vice President, General Counsel and Secretary