SEC Company Response from ACCURAY INC (ARAY) (CIK 0001138723) (ARAY) — Feb 7, 2007
ACCURAY INC (ARAY) (CIK 0001138723)
Date: Feb. 7, 2007 · CIK: 0001138723 · Accession: 0001047469-07-000725
AI Filing Summary & Sentiment
File numbers found in text: 333-138622
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CORRESP
1
filename1.htm
[Accuray Letterhead]
February 6,
2007
VIA EDGAR AND FACSIMILE—(202) 772-9218
Securities
and Exchange Commission
Mail Stop 6010
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Jay Mumford
Perry Hindin, Special Counsel
Kristin Lochhead
Brian Cascio
Re:Accuray Incorporated
Registration Statement on Form S-1 (Registration No. 333-138622)
Ladies and Gentlemen:
In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on
Form S-1 (No. 333-138622) (the "Registration Statement") of Accuray Incorporated (the "Company"). We
respectfully request that the Registration Statement become effective as of 4:00 p.m., Washington, D.C. time, on February 7, 2007, or as soon as practicable thereafter. Once the
Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Laura Bushnell at (650) 463-2645.
The
Company acknowledges the following:
•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;
•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
•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.
Please
do not hesitate to call Laura Bushnell at (650) 463-2645 if you have any questions regarding this request.
Very truly yours,
/s/ EUAN S. THOMSON, PH.D. Euan S. Thomson, Ph.D.
President and Chief Executive Officer