CORRESP Filing
zSpace, Inc.
Date: July 30, 2025 · CIK: 0001637147 · Accession: 0001104659-25-072044
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-288978
Letter
zSpace, Inc. 55 Nicholson Lane
San Jose, California 95134
July 30, 2025
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
Filed July 25, 2025
File No. 333-288978
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 above-captioned registration statement (the "Registration Statement") so that such Registration Statement will become effective as of 4:00 p.m. eastern time on Friday, August 1, 2025, 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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CORRESP 1 filename1.htm zSpace, Inc. 55 Nicholson Lane San Jose, California 95134 July 30, 2025 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 Filed July 25, 2025 File No. 333-288978 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 above-captioned registration statement (the "Registration Statement") so that such Registration Statement will become effective as of 4:00 p.m. eastern time on Friday, August 1, 2025, 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