SEC Company Response from ServiceNow, Inc. (NOW) (CIK 0001373715) (NOW) — Jun 26, 2012
ServiceNow, Inc. (NOW) (CIK 0001373715)
Date: June 26, 2012 · CIK: 0001373715 · Accession: 0001193125-12-283567
AI Filing Summary & Sentiment
File numbers found in text: 001-35580, 333-180486
Letter
Acceleration Request
SERVICENOW, INC.
12225 El Camino Real, Suite 100
San Diego, California 92130
June 26, 2012
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attention:
Barbara C. Jacobs, Assistant Director
Matthew Crispino, Staff Attorney
David Edgar, Staff Accountant
Patrick Gilmore, Accounting Branch Chief
Re:
ServiceNow, Inc. Form S-1 Registration Statement (File No. 333-180486)
originally filed March 30, 2012, as amended, and corresponding Registration
Statement on Form 8-A (File No. 001-35580)
Acceleration Request
Requested Date:
June 28, 2012
Requested Time:
4:00 PM Eastern Time
Ladies and Gentlemen:
ServiceNow, 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 Robert A. Freedman or Gordon K. Davidson, 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. Freedman at (650) 335-7292, or in his absence, Mr. Davidson at (650) 335-7237.
Sincerely,
SERVICENOW, INC.
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CORRESP
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filename1.htm
Acceleration Request
SERVICENOW, INC.
12225 El Camino Real, Suite 100
San Diego, California 92130
June 26, 2012
VIA EDGAR
United States
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attention:
Barbara C. Jacobs, Assistant Director
Matthew Crispino, Staff Attorney
David Edgar, Staff Accountant
Patrick Gilmore, Accounting Branch Chief
Re:
ServiceNow, Inc. Form S-1 Registration Statement (File No. 333-180486)
originally filed March 30, 2012, as amended, and corresponding Registration
Statement on Form
8-A (File No. 001-35580)
Acceleration Request
Requested Date:
June 28, 2012
Requested Time:
4:00 PM Eastern Time
Ladies and Gentlemen:
ServiceNow, 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 Robert A. Freedman or Gordon K. Davidson, 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. Freedman at (650) 335-7292, or in his absence, Mr. Davidson at (650) 335-7237.
Sincerely,
SERVICENOW, INC.
By:
/s/ MICHAEL P. SCARPELLI
Michael P. Scarpelli
Chief Financial Officer
cc:
Frank Slootman, Chief Executive Officer
Robert Specker, Esq., General Counsel
Ethan Christensen, Esq., Vice President, Legal
ServiceNow, Inc.
Gordon
Davidson, Esq.
Dawn Belt, Esq.
Fenwick & West LLP