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SEC Company Response from VISA INC. (V) (CIK 0001403161) (V) — Sep 12, 2007

VISA INC. (V) (CIK 0001403161)
Date: Sept. 12, 2007 · CIK: 0001403161 · Accession: 0001193125-07-200050

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File numbers found in text: 333-143966

Date
September 12, 2007
Author
William M. Sheedy
Form
CORRESP
Company
VISA INC. (V) (CIK 0001403161)

Letter

SEC acceleration request

September 12, 2007

BY EDGAR AND FACSIMILE

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Mail Stop 4561

Washington, D.C. 20549

Attention:

Elaine Wolff

Michael McTiernan

Re:

Visa Inc.

Registration Statement on Form S-4 (File No. 333-143966)

Ladies and Gentlemen:

Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, Visa Inc. (the “Company”) hereby requests that the effective time of the above-referenced registration statement be accelerated to 4:00 p.m. (EST) on Thursday, September 13, 2007, or as soon thereafter on such date as practicable.

The Company hereby acknowledges that:

•

should the Securities and Exchange Commission (the “Commission”) or 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 Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Company may not assert 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.

Very truly yours,
Visa Inc.

Show Raw Text
CORRESP
1
filename1.htm

SEC acceleration request

 September 12, 2007

 BY EDGAR AND FACSIMILE

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, N.E.

 Mail Stop 4561

 Washington, D.C. 20549

 Attention:

Elaine Wolff

Michael McTiernan

 Re:

Visa Inc.

Registration Statement on Form S-4 (File No. 333-143966)

 Ladies and Gentlemen:

 Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, Visa Inc. (the “Company”) hereby requests that
the effective time of the above-referenced registration statement be accelerated to 4:00 p.m. (EST) on Thursday, September 13, 2007, or as soon thereafter on such date as practicable.

 The Company hereby acknowledges that:

•

 should the Securities and Exchange Commission (the “Commission”) or 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 Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

 the Company may not assert 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.

 Very truly yours,

 Visa Inc.

 /s/ William M. Sheedy

 William M. Sheedy

 Executive Vice President