SEC Company Response from TRUPANION, INC. (TRUP) (CIK 0001371285) (TRUP) — Jul 15, 2014
TRUPANION, INC. (TRUP) (CIK 0001371285)
Date: July 15, 2014 · CIK: 0001371285 · Accession: 0001193125-14-269015
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File numbers found in text: 333-196814
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CORRESP 1 filename1.htm CORRESP July 15, 2014 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington D.C. 20549-3561 Attention: Scott Foley Re: Acceleration Request of Trupanion, Inc. Registration Statement on Form S-1 (File No. 333-196814) Ladies and Gentlemen: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as the representatives of the several underwriters, hereby join in the request of Trupanion, Inc. for acceleration of the effective time of the above-referenced Registration Statement, as amended, so that it may be declared effective Thursday, July 17, 2014, at 4:15 p.m. Eastern Time, or as soon thereafter as practicable. In connection with this acceleration request and pursuant to Rule 460 under the Securities Act, we hereby advise you that the Preliminary Prospectus, dated July 7, 2014, was distributed by the several underwriters approximately as follows from July 7, 2014 through the date hereof: To Whom Distributed Number of Copies Retail Investors 3,007 Institutional Investors 1,172 Total 4,179 The undersigned, as the representatives of the several underwriters, hereby represent that we have complied and will comply with the requirements of Rule 15c2-8 of the Securities Exchange Act of 1934, as amended, in connection with the above proposed offering. Sincerely yours, RBC Capital Markets, LLC /s/ Jennifer Caruso Name: Jennifer Caruso Title: Director Barclays Capital Inc. /s/ Jason van Itallie Name: Jason van Itallie Title: Managing Director Stifel, Nicolaus & Company, Incorporated /s/ Daniel J. Covatta Name: Daniel J. Covatta Title: Managing Director