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SEC Company Response from VEEVA SYSTEMS INC (VEEV) (CIK 0001393052) (VEEV) — Oct 10, 2013

VEEVA SYSTEMS INC (VEEV) (CIK 0001393052)
Date: Oct. 10, 2013 · CIK: 0001393052 · Accession: 0001193125-13-396555

AI Filing Summary & Sentiment

File numbers found in text: 333-191085

Date
October 10, 2013
Author
By
Form
CORRESP
Company
VEEVA SYSTEMS INC (VEEV) (CIK 0001393052)

Letter

VIA EDGAR Division of Corporation Finance Attention: Ivan Griswold Re: Veeva Systems Inc. Registration Statement on Form S-1 (File No. 333-191085) Request for Acceleration of Effective Date

Dear Mr. Griswold:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Veeva Systems Inc. (the “Registrant”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-191085) (the “Registration Statement”), so that it may become effective at 4:00 p.m. Eastern Time on October 15, 2013, or as soon thereafter as practicable.

The Registrant hereby acknowledges that:

(i) should the Securities and Exchange Commission (the “Commission”) or the staff (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

(ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(iii) the Registrant may not assert comments of the Commission or the Staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[Signature Page Follows]

Sincerely,
Veeva Systems Inc.

Show Raw Text
CORRESP
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filename1.htm

Company Acceleration Request

 October 10, 2013

VIA EDGAR

 U.S. Securities and
Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-3720

Attention: Ivan Griswold

Re:

Veeva Systems Inc.

Registration Statement on Form S-1 (File No. 333-191085)

Request for Acceleration of Effective Date

Dear Mr. Griswold:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Veeva Systems Inc. (the “Registrant”) hereby requests
acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-191085) (the “Registration Statement”), so that it may become effective at 4:00 p.m. Eastern Time on October 15, 2013, or as
soon thereafter as practicable.

 The Registrant
hereby acknowledges that:

 (i) should the Securities and Exchange
Commission (the “Commission”) or the staff (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with
respect to the Registration Statement;

 (ii) the action of the
Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
Statement; and

 (iii) the Registrant may not assert comments of
the Commission or the Staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 [Signature Page Follows]

 1

 Sincerely,

 Veeva Systems Inc.

 By:

 /s/ Timothy S. Cabral

 Timothy S. Cabral

 Chief Financial Officer

 2