CORRESP Filing
StubHub Holdings, Inc.
Date: Sept. 12, 2025 · CIK: 0001337634 · Accession: 0001193125-25-202179
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-286000
Letter
Re: StubHub Holdings, Inc.
StubHub Holdings, Inc. 175 Greenwich Street, 59th Floor New York, New York 10007 September 12, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services 100 F Street, N.E. Washington, D.C. 20549-6010
Attention: Joel Parker
Alyssa Wall
Erin Jaskot
Registration Statement on Form S-1, as amended (File No. 333-286000)
Acceleration Request To the addressees set forth above: In accordance with Rule 461 under the Securities Act of 1933, as amended, StubHub Holdings, Inc. (the “ Company ”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-286000) (as amended, the “ Registration Statement ”). The Company respectfully requests that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on September 16, 2025, or as soon as practicable thereafter, or at such other time as the Company or its legal counsel may request by telephone to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Michael Benjamin at (212) 906-1311 or Alison Haggerty at (212) 906-1320. Thank you for your assistance in this matter. [ Signature Pages Follow ]
Very truly yours,
StubHub Holdings, Inc.
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CORRESP 1 filename1.htm CORRESP StubHub Holdings, Inc. 175 Greenwich Street, 59th Floor New York, New York 10007 September 12, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services 100 F Street, N.E. Washington, D.C. 20549-6010 Attention: Joel Parker Alyssa Wall Erin Jaskot Re: StubHub Holdings, Inc. Registration Statement on Form S-1, as amended (File No. 333-286000) Acceleration Request To the addressees set forth above: In accordance with Rule 461 under the Securities Act of 1933, as amended, StubHub Holdings, Inc. (the “ Company ”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-286000) (as amended, the “ Registration Statement ”). The Company respectfully requests that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on September 16, 2025, or as soon as practicable thereafter, or at such other time as the Company or its legal counsel may request by telephone to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Michael Benjamin at (212) 906-1311 or Alison Haggerty at (212) 906-1320. Thank you for your assistance in this matter. [ Signature Pages Follow ] Very truly yours, StubHub Holdings, Inc. By: /s/ Eric Baker Name: Eric Baker Title: Chief Executive Officer cc: Mark Streams, StubHub Holdings, Inc. Connie James, StubHub Holdings, Inc. Michael Benjamin, Latham & Watkins LLP Tad J. Freese, Latham & Watkins LLP Alison A. Haggerty, Latham & Watkins LLP Adam Gelardi, Latham & Watkins LLP Dave Peinsipp, Cooley LLP Kristin VanderPas, Cooley LLP Denny Won, Cooley LLP [ Signature Page to Issuer Acceleration Request ]