SEC Comment Letter for Upland Software, Inc. (UPLD) (CIK 0001505155) (UPLD) — Dec 18, 2018
Upland Software, Inc. (UPLD) (CIK 0001505155)
Date: Dec. 18, 2018 · CIK: 0001505155 · Accession: 0000000000-18-038393
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Reasoning
File numbers found in text: 333-228767
Letter
December 18, 2018 John T. McDonald Chief Executive Officer Upland Software, Inc. 401 Congress Avenue, Suite 1850 Austin, TX 78701 Re:Upland Software, Inc. Registration Statement on Form S-3 Filed December 12, 2018 File No. 333-228767 Dear Mr. McDonald : This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Edwin Kim, Attorney-Advisor, at (202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services cc: Steve Tyndall, Esq.
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December 18, 2018
John T. McDonald
Chief Executive Officer
Upland Software, Inc.
401 Congress Avenue, Suite 1850
Austin, TX 78701
Re:Upland Software, Inc.
Registration Statement on Form S-3
Filed December 12, 2018
File No. 333-228767
Dear Mr. McDonald :
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Edwin Kim, Attorney-Advisor, at (202) 551-3297 or Jan Woo, Legal
Branch Chief, at (202) 551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services
cc: Steve Tyndall, Esq.