SEC Company Response from UNICA CORP (CIK 0001138804) — Jul 29, 2005
UNICA CORP (CIK 0001138804)
Date: July 29, 2005 · CIK: 0001138804 · Accession: 0000950135-05-004279
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File numbers found in text: 333-120615
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CORRESP
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ACCELERATION REQUEST - DEUTSCHE BANK SECURITIES
DEUTSCHE BANK SECURITIES INC.
60 Wall Street, 4th Floor
New York, New York 10005
July 29, 2005
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Re:
Unica Corporation
Registration Statement on Form S-1
File No. 333-120615
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities
Act”), the undersigned, as representatives of the several underwriters (the “Underwriters”) in
connection with the offering pursuant to the above-captioned Registration Statement, hereby join in
the request of Unica Corporation that the effective date of the above-captioned Registration
Statement be accelerated to 3:00 p.m. on August 2, 2005, or as soon thereafter as practicable.
In connection with this acceleration request and pursuant to Rule 460 under the Securities
Act, please be advised that between July 19, 2005 and the date hereof, copies of the preliminary
prospectus dated July 18, 2005 were distributed as follows:
To Whom Distributed
Number of Copies
Underwriters
3500
Institutional Investors
925
Individual Investors
650
Rating Agencies
2
Others
1
The undersigned, as representatives of the several Underwriters, have and will, and each
Underwriter and dealer has advised the undersigned that it has and will, comply with Rule 15c2-8
promulgated under the Securities Exchange Act of 1934, as amended.
Very truly yours,
DEUTSCHE BANK SECURITIES INC.
WACHOVIA CAPITAL MARKETS, LLC
CIBC WORLD MARKETS CORP.
NEEDHAM & COMPANY, LLC
As Representatives of the several Underwriters
By:
Deutsche Bank Securities Inc.
By:
/s/ Brian Truesdale
Brian Truesdale