Correspondence 0001104659-24-114370 from zSpace, Inc. (ZSPC)
zSpace, Inc.
Date: Nov. 5, 2024 · CIK: 0001637147 · Accession: 0001104659-24-114370
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-280427
Letter
zSpace, Inc.
2050 Gateway Place
Suite 100-302
San Jose, CA 95110
November 5, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Re: zSpace, Inc. (the “Company”)
Registration Statement on Form S-1 originally filed June 24, 2024
(File No. 333-280427) (as amended, the “Registration Statement”)
Ladies and Gentlemen:
The Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the Registration Statement so that such Registration Statement will become effective as of 5:00 p.m. eastern time on Thursday, November 7, 2024, or as soon thereafter as practicable.
If there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may make an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461.
We acknowledge that a declaration by the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, that the Registration Statement is effective does not foreclose the Commission from taking any action with respect to the Registration Statement. We further acknowledge that such a declaration of effectiveness does not relieve the Company from our full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement. We understand that we may not assert staff comments to the Registration Statement or the declaration of effectiveness by the Commission as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you have any questions, please contact M. Ali Panjwani, Esq., at (212) 326-0820, from the Company’s legal counsel, Pryor Cashman LLP.
Very truly yours,
zSpace, Inc.
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zSpace, Inc.
2050 Gateway Place
Suite 100-302
San Jose, CA 95110
November 5, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Re: zSpace, Inc.
(the “Company”)
Registration Statement on Form S-1 originally
filed June 24, 2024
(File No. 333-280427) (as amended, the
“Registration Statement”)
Ladies and Gentlemen:
The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the Registration
Statement so that such Registration Statement will become effective as of 5:00 p.m. eastern time on Thursday, November 7, 2024,
or as soon thereafter as practicable.
If there is any change in
the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may make an oral
request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461.
We acknowledge that a declaration
by the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, that the
Registration Statement is effective does not foreclose the Commission from taking any action with respect to the Registration Statement.
We further acknowledge that such a declaration of effectiveness does not relieve the Company from our full responsibility for the adequacy
and accuracy of the disclosure in the Registration Statement. We understand that we may not assert staff comments to the Registration
Statement or the declaration of effectiveness by the Commission as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.
If you have any questions,
please contact M. Ali Panjwani, Esq., at (212) 326-0820, from the Company’s legal counsel, Pryor Cashman LLP.
Very truly yours,
zSpace, Inc.
By:
/s/
Paul Kellenberger
Name: Paul
Kellenberger
Title: CEO
cc: M.
Ali Panjwani, Esq.
Pryor Cashman LLP