SEC Company Response from GoDaddy Inc. (GDDY) (CIK 0001609711) (GDDY) — Mar 27, 2015
GoDaddy Inc. (GDDY) (CIK 0001609711)
Date: March 27, 2015 · CIK: 0001609711 · Accession: 0001193125-15-109648
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File numbers found in text: 333-196615
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CORRESP
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filename1.htm
CORRESP
March 27, 2015
VIA EDGAR
Division of Corporation Finance
U.S. Securities & Exchange Commission
100 F Street,
N.E.
Washington, D.C. 20549
Attention:
Luna Bloom
Melissa Kindelan
Patrick Gilmore
Re:
GoDaddy Inc.
Registration Statement on Form S-1
File No. 333-196615
Acceleration Request
Requested Date:
March 31, 2015
Requested Time:
4:00 P.M. Eastern Time
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, GoDaddy Inc. (the “Company”) hereby requests that the
above-referenced Registration Statement on Form S-1 (File No. 333-196615) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or at such later
time as the Company or its counsel may orally request via telephone call to the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”). Once the
Registration Statement has been declared effective, please orally confirm that event with our counsel, Wilson Sonsini Goodrich & Rosati, P.C., by calling Allison B. Spinner at (650) 565-3765.
In connection with the acceleration request, the Company hereby acknowledges that:
•
should the Commission or 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;
•
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 Registration Statement; 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.
* * * *
Sincerely,
GODADDY INC.
/s/ Blake Irving
Blake Irving
Chief Executive Officer
cc:
Nima Kelly, GoDaddy Inc.
Jeffrey D. Saper, Wilson Sonsini Goodrich & Rosati, P.C.
Allison B. Spinner, Wilson Sonsini Goodrich & Rosati, P.C.
Alan F. Denenberg, Davis Polk & Wardwell LLP
Sarah K. Solum, Davis Polk & Wardwell LLP