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: 0001193125-15-109656
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File numbers found in text: 333-196615
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CORRESP 1 filename1.htm CORRESP Morgan Stanley & Co. LLC 1585 Broadway New York, New York 10036 J.P. Morgan Securities LLC 383 Madison Avenue New York, New York 10179 Citigroup Global Markets Inc. 388 Greenwich Street New York, New York 10013 VIA EDGAR March 27, 2015 Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Luna Bloom Melissa Kindelan Patrick Gilmore Re: GoDaddy Inc. Registration Statement on Form S-1 Registration File No. 333-196615 Ladies and Gentlemen: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of GoDaddy Inc. (the “Company”) for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 4:00 PM, Washington, D.C. time, on March 31, 2015, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Wilson Sonsini Goodrich & Rosati, P.C., request by telephone that such Registration Statement be declared effective. Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated March 19, 2015: (i) Dates of distribution: March 19, 2015 through the date hereof (ii) Number of prospective underwriters to which the preliminary prospectus was furnished: 11 (iii) Number of prospectuses furnished to investors: approximately 6,866 (iv) Number of prospectuses distributed to others, including the Company, the Company’s counsel, independent accountants, and underwriters’ counsel: approximately 265 We, the undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. Very truly yours, MORGAN STANLEY & CO. LLC J.P. MORGAN SECURITIES LLC CITIGROUP GLOBAL MARKETS INC. Acting severally on behalf of themselves and the several Underwriters By: MORGAN STANLEY & CO. LLC By: /s/ Colin R. Stewart Name: Colin R. Stewart Title: Managing Director By: J.P. MORGAN SECURITIES LLC By: /s/ Gregor Feige Name: Gregor Feige Title: Executive Director By: CITIGROUP GLOBAL MARKETS INC. By: /s/ Israel Halpert Name: Israel Halpert Title: Director [Signature Page to Underwriters’ Acceleration Request]