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: 0001193125-14-269026
AI Filing Summary & Sentiment
File numbers found in text: 001-36537, 333-196814
Letter
TRUPANION, INC.
907 NW Ballard Way
Seattle, WA 98107
July 15, 2014
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attention:
Jeffrey Riedler
Scott Foley
John Krug
Donald Abbott
Lisa Vanjoske
Re:
Trupanion, Inc. Registration Statement on Form S-1 (File No. 333-196814) originally filed June 16, 2014, as amended, and corresponding Registration Statement on Form 8-A (File No. 001-36537) filed July 11, 2014
Acceleration Request:
Requested Date: July 17, 2014
Requested Time: 4:15 PM Eastern Time
Ladies and Gentlemen:
Trupanion, Inc. (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to declare the above-captioned Registration Statements on Form S-1 and Form 8-A effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable.
The Registrant hereby authorizes James D. Evans or Amanda L. Rose, both of whom are attorneys with the Registrant’s outside legal counsel, Fenwick & West LLP, to orally modify or withdraw this request for acceleration.
The Registrant hereby acknowledges that:
•
should the Commission or the staff of the Commission (the “Staff”), 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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
•
the Registrant 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 Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Evans at (206) 389-4559, or in his absence, Ms. Rose at (206) 389-4553.
Sincerely,
TRUPANION, INC.
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CORRESP 1 filename1.htm CORRESP TRUPANION, INC. 907 NW Ballard Way Seattle, WA 98107 July 15, 2014 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549 Attention: Jeffrey Riedler Scott Foley John Krug Donald Abbott Lisa Vanjoske Re: Trupanion, Inc. Registration Statement on Form S-1 (File No. 333-196814) originally filed June 16, 2014, as amended, and corresponding Registration Statement on Form 8-A (File No. 001-36537) filed July 11, 2014 Acceleration Request: Requested Date: July 17, 2014 Requested Time: 4:15 PM Eastern Time Ladies and Gentlemen: Trupanion, Inc. (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to declare the above-captioned Registration Statements on Form S-1 and Form 8-A effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable. The Registrant hereby authorizes James D. Evans or Amanda L. Rose, both of whom are attorneys with the Registrant’s outside legal counsel, Fenwick & West LLP, to orally modify or withdraw this request for acceleration. The Registrant hereby acknowledges that: • should the Commission or the staff of the Commission (the “Staff”), 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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and • the Registrant 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 Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Evans at (206) 389-4559, or in his absence, Ms. Rose at (206) 389-4553. Sincerely, TRUPANION, INC. By: /s/ Darryl Rawlings Darryl Rawlings Chief Executive Officer and President cc: Michael Banks, Chief Financial Officer Asher Bearman, Esq., General Counsel and Secretary Trupanion, Inc. Alan C. Smith, Esq. James D. Evans, Esq. Amanda L. Rose, Esq. Fenwick & West LLP