SEC Company Response from BILL Holdings, (BILL) — Dec 9, 2019
BILL Holdings, Inc.
Date: Dec. 9, 2019 · CIK: 0001786352 · Accession: 0001193125-19-309244
AI Filing Summary & Sentiment
File numbers found in text: 001-39149, 333-234730
Letter
Bill.com Holdings, Inc.
1810 Embarcadero Road
Palo Alto, California 94303
December 9, 2019
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Attention:
Kathleen Krebs, Special Counsel Jeff Kauten, Staff Attorney Christine Dietz, Senior Staff Accountant Eiko Yaoita Pyles, Staff Accountant
Re:
Bill.com Holdings, Inc. Registration Statement on Form S-1 (File No. 333-234730) originally filed November 15, 2019, as amended, and corresponding Registration Statement on Form 8-A (File No. 001-39149) filed December 3, 2019
Requested Date: December 11, 2019
Requested Time: 4:00 PM Eastern Time
Ladies and Gentlemen:
Bill.com Holdings, Inc. (the “Registrant”) hereby requests that the Securities and Exchange Commission take appropriate action to declare the above-captioned Registration Statements on Form S-1 and Form 8-A effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable.
The Registrant hereby authorizes James D. Evans or Nicolas H. R. Dumont, both of whom are attorneys with the Registrant’s outside legal counsel, Fenwick & West LLP, to orally modify or withdraw this request for acceleration.
The Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Evans at (206) 389-4559 or, in his absence, Mr. Dumont at (212) 430-2679.
* * *
Sincerely,
BILL.COM HOLDINGS, INC.
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CORRESP 1 filename1.htm CORRESP Bill.com Holdings, Inc. 1810 Embarcadero Road Palo Alto, California 94303 December 9, 2019 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549 Attention: Kathleen Krebs, Special Counsel Jeff Kauten, Staff Attorney Christine Dietz, Senior Staff Accountant Eiko Yaoita Pyles, Staff Accountant Re: Bill.com Holdings, Inc. Registration Statement on Form S-1 (File No. 333-234730) originally filed November 15, 2019, as amended, and corresponding Registration Statement on Form 8-A (File No. 001-39149) filed December 3, 2019 Requested Date: December 11, 2019 Requested Time: 4:00 PM Eastern Time Ladies and Gentlemen: Bill.com Holdings, Inc. (the “Registrant”) hereby requests that the Securities and Exchange Commission take appropriate action to declare the above-captioned Registration Statements on Form S-1 and Form 8-A effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable. The Registrant hereby authorizes James D. Evans or Nicolas H. R. Dumont, both of whom are attorneys with the Registrant’s outside legal counsel, Fenwick & West LLP, to orally modify or withdraw this request for acceleration. The Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Evans at (206) 389-4559 or, in his absence, Mr. Dumont at (212) 430-2679. * * * Sincerely, BILL.COM HOLDINGS, INC. By: /s/ Raj Aji Raj Aji General Counsel, Chief Compliance Officer and Secretary cc: René Lacerte, President and Chief Executive Officer John Rettig, Chief Financial Officer and Executive Vice President, Finance and Operations Bill.com Holdings, Inc. Mark C. Stevens, Esq. James D. Evans, Esq. Dawn H. Belt, Esq. Nicolas H.R. Dumont, Esq. Fenwick & West LLP [Signature Page to Company Acceleration Request Letter]