CORRESP Filing
StubHub Holdings, Inc.
Date: Sept. 12, 2025 · CIK: 0001337634 · Accession: 0001193125-25-202186
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File numbers found in text: 333-286000
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CORRESP 1 filename1.htm CORRESP September 12, 2025 United States Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services 100 F Street, N.E. Washington, DC 20549 Attn: Joel Parker Alyssa Wall Erin Jaskot Re: StubHub Holdings, Inc. (the “ Registrant ”) Registration Statement on Form S-1, as amended (File No. 333-286000) Request for Acceleration Ladies and Gentlemen: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as representatives of the several underwriters, hereby join in the request of the Registrant that the effectiveness of the above-captioned registration statement (the “Registration Statement”) be accelerated to 4:00 p.m. Eastern Time, on Tuesday, September 16, 2025 or as soon thereafter as practicable. Pursuant to Rule 460 under the Securities Act, please be advised that we, as representatives of the several underwriters, will take reasonable steps to secure adequate distribution of the preliminary prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement. We wish to advise you that the participating underwriters have informed us that they have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [signature page follows] Very truly yours, J.P. MORGAN SECURITIES LLC GOLDMAN SACHS & CO. LLC As representatives of the Underwriters J.P. MORGAN SECURITIES LLC By: /s/ Olivia Sem Name: Olivia Sem Title: Vice President GOLDMAN SACHS & CO. LLC By: /s/ William Connolly Name: William Connolly Title: Managing Director [Signature Page to Acceleration Request Letter]