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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

AI Filing Summary & Sentiment

File numbers found in text: 333-196615

Date
March 27, 2015
Author
/s/ Blake Irving
Form
CORRESP
Company
GoDaddy Inc. (GDDY) (CIK 0001609711)

Letter

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.

Show Raw Text
CORRESP
1
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