SEC Comment Letter for UNICA CORP (CIK 0001138804) — May 13, 2005
UNICA CORP (CIK 0001138804)
Date: May 13, 2005 · CIK: 0001138804 · Accession: 0000000000-05-023826
AI Filing Summary & Sentiment
File numbers found in text: 333-120615
Letter
Mail Stop 4-6 May 12, 2005 Mr. Yuchun Lee Chief Executive Officer Unica Corporation Reservoir Place North 170 Tracer Lane Waltham, Massachusetts 02451-1379
Re: Unica Corporation Amendment No. 5 to Registration Statement on Form S-1 File No. 333-120615
Dear Mr. Lee:
We have reviewed your amended filing and have the following comments.
Principal and Selling Stockholders
1. Please update your information in this section to a more recent practicable date than March 31. Please see Items 403 and 507 of Regulation S-K.
Item 16. Exhibits.
Opinion of Wilmer Cutler Pickering Hale and Dorr LLP
2. We note that counsel has limited their legal opinion to, among other things, the General Corporation Law of the State of Delaware. Please confirm to us in writing that such reference to the General Corporation Law of the State of Delaware includes the statutory provisions and also all applicable provisions of the Delaware Constitution and reported judicial decisions interpreting these laws. Please see Section VII.A.14 of our Current Issues and Rulemaking Projects Outline dated November 14, 2000 for additional guidance.
* * * *
As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Kari Jin at (202) 551-3481, or Craig Wilson, Senior Assistant Chief Accountant, at (202) 551-3226, if you have questions or comments on the financial statements and related matters. Please contact Daniel Lee at (202) 551-3477 with any other questions. If you need further assistance, you may contact me at (202) 551-3730.
Sincerely,
Barbara C. Jacobs
Assistant Director
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Mail Stop 4-6
May 12, 2005
Mr. Yuchun Lee
Chief Executive Officer
Unica Corporation
Reservoir Place North
170 Tracer Lane
Waltham, Massachusetts 02451-1379
Re: Unica Corporation
Amendment No. 5 to Registration Statement on Form S-1
File No. 333-120615
Dear Mr. Lee:
We have reviewed your amended filing and have the following
comments.
Principal and Selling Stockholders
1. Please update your information in this section to a more recent
practicable date than March 31. Please see Items 403 and 507 of
Regulation S-K.
Item 16. Exhibits.
Opinion of Wilmer Cutler Pickering Hale and Dorr LLP
2. We note that counsel has limited their legal opinion to, among
other things, the General Corporation Law of the State of
Delaware.
Please confirm to us in writing that such reference to the General
Corporation Law of the State of Delaware includes the statutory
provisions and also all applicable provisions of the Delaware
Constitution and reported judicial decisions interpreting these
laws.
Please see Section VII.A.14 of our Current Issues and Rulemaking
Projects Outline dated November 14, 2000 for additional guidance.
* * * *
As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with
marked
copies of the amendment to expedite our review. Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review. Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.
You may contact Kari Jin at (202) 551-3481, or Craig Wilson,
Senior Assistant Chief Accountant, at (202) 551-3226, if you have
questions or comments on the financial statements and related
matters. Please contact Daniel Lee at (202) 551-3477 with any
other
questions. If you need further assistance, you may contact me at
(202) 551-3730.
Sincerely,
Barbara C. Jacobs
Assistant Director
cc: Via Facsimile
Peter B. Tarr, Esq.
Mark L. Johnson, Esq.
Wilmer Cutler Pickering Hale and Dorr LLP
60 State Street
Boston, Massachusetts 02109
Telephone: (617) 526-6000
Facsimile: (617) 526-5000
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