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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

Date
September 12, 2025
Author
Vice President
Form
CORRESP
Company
StubHub Holdings, Inc.

Letter

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]

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

Very truly yours,
J.P. MORGAN SECURITIES LLC

Show Raw Text
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]