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SEC Company Response from OOMA INC (OOMA) (CIK 0001327688) (OOMA) — Jul 14, 2015

OOMA INC (OOMA) (CIK 0001327688)
Date: July 14, 2015 · CIK: 0001327688 · Accession: 0001193125-15-252181

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File numbers found in text: 333-204975

Date
July 14, 2015
Author
By
Form
CORRESP
Company
OOMA INC (OOMA) (CIK 0001327688)

Letter

Company Acceleration Request

OOMA, INC.

1880 Embarcadero Road

Palo Alto, CA 94303

July 14, 2015

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn:

Barbara C. Jacobs

Mitchell Austin

Re:

Ooma, Inc. Acceleration Request

Acceleration Request

Requested Date:

July 16, 2015

Requested Time:

4:30 p.m. Eastern Time

Ladies and Gentlemen:

Ooma, Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to declare the Company’s Registration Statement on Form S-1 (File No. 333-204975), as amended, effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable.

The Company hereby authorizes Andrew D. Thorpe or Christopher J. Austin, both of whom are attorneys with the Company’s outside legal counsel, Orrick, Herrington & Sutcliffe LLP, to orally modify or withdraw this request for acceleration.

In connection with this acceleration request, the Company hereby acknowledges that:

•

should the Commission or the staff of the Commission, 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 the 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.

The Company requests that it be notified of such effectiveness by a telephone call to Mr. Thorpe at (415) 773-5970, or in his absence, Mr. Austin at (212) 506-5234.

[Signature page follows]

Sincerely,
OOMA, INC.

Show Raw Text
CORRESP
1
filename1.htm

Company Acceleration Request

 OOMA, INC.

1880 Embarcadero Road

 Palo Alto,
CA 94303

 July 14, 2015

VIA EDGAR

 U.S.
Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Attn:

 Barbara C. Jacobs

Mitchell Austin

Re:

 Ooma, Inc. Acceleration Request

 Acceleration Request

            Requested Date:

July 16, 2015

            Requested Time:

4:30 p.m. Eastern Time

 Ladies and Gentlemen:

Ooma, Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the
“Commission”) take appropriate action to declare the Company’s Registration Statement on Form S-1 (File No. 333-204975), as amended, effective at the “Requested Date” and “Requested Time”
set forth above or as soon thereafter as practicable.

 The Company hereby authorizes Andrew D. Thorpe or Christopher J. Austin, both of
whom are attorneys with the Company’s outside legal counsel, Orrick, Herrington & Sutcliffe LLP, to orally modify or withdraw this request for acceleration.

In connection with this acceleration request, the Company hereby acknowledges that:

•

should the Commission or the staff of the Commission, 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 the 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.

 The Company requests that it be notified of such effectiveness by a telephone call to
Mr. Thorpe at (415) 773-5970, or in his absence, Mr. Austin at (212) 506-5234.

 [Signature page follows]

 Sincerely,

OOMA, INC.

 By:

 /s/ Spencer D. Jackson

 Name: Spencer D. Jackson

Title: Vice President & General Counsel

cc:

 Eric T. Stang, Ooma, Inc.

 Andrew D. Thorpe, Orrick, Herrington & Sutcliffe, LLP

 Christopher J. Austin, Orrick, Herrington & Sutcliffe, LLP

 Andrew S. Williamson, Cooley LLP