SEC Comment Letter for GoDaddy Inc. (GDDY) (CIK 0001609711) (GDDY) — Dec 2, 2015
GoDaddy Inc. (GDDY) (CIK 0001609711)
Date: Dec. 2, 2015 · CIK: 0001609711 · Accession: 0000000000-15-056186
AI Filing Summary & Sentiment
File numbers found in text: 333-208197
Letter
Mail Stop 4561 December 2, 2015 Blake J. Irving Chief Executive Officer GoDaddy Inc. 14455 N. Hayden Road Scottsdale, Arizona 85260
Re: GoDaddy Inc. Registration Statement on Form S-1 Filed November 25, 2015 File No. 333-208197
Dear Mr. Irving :
This is to advise you that we have not reviewed and will not review your registration statement .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h 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 th e 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.
Please refer to Rule 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the
Blake J. Irving GoDaddy Inc. December 2, 2015 Page 2
fact that those requesting acceleration are aware of their respective responsibilities unde r the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .
Please contact Ji Shin, Attorney -Advisor, at (202) 551 -3579, or me at (202) 551 -3487 with any questions.
Sincerely,
/s/ Barbara C. Jacobs
Show Raw Text
Mail Stop 4561 December 2, 2015 Blake J. Irving Chief Executive Officer GoDaddy Inc. 14455 N. Hayden Road Scottsdale, Arizona 85260 Re: GoDaddy Inc. Registration Statement on Form S-1 Filed November 25, 2015 File No. 333-208197 Dear Mr. Irving : This is to advise you that we have not reviewed and will not review your registration statement . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h 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 th e 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. Please refer to Rule 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the Blake J. Irving GoDaddy Inc. December 2, 2015 Page 2 fact that those requesting acceleration are aware of their respective responsibilities unde r the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities . Please contact Ji Shin, Attorney -Advisor, at (202) 551 -3579, or me at (202) 551 -3487 with any questions. Sincerely, /s/ Barbara C. Jacobs Barbara C. Jacobs Assistant Director Office of Information Technologies and Services cc: Jeffrey D. Saper, Esq. Wilson Sonsini Goodrich & Rosati, P.C