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SEC Company Response from BILL Holdings, (BILL) — Dec 9, 2019

BILL Holdings, Inc.
Date: Dec. 9, 2019 · CIK: 0001786352 · Accession: 0001193125-19-309254

AI Filing Summary & Sentiment

File numbers found in text: 333-234730

Date
December 9, 2019
Author
Goldman Sachs & Co. LLC
Form
CORRESP
Company
BILL Holdings, Inc.

Letter

Re:

December 9, 2019

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Bill.com Holdings, Inc.

Registration Statement on Form S-1

File No. 333-234730

Acceleration Request

Requested Date:

December 11, 2019

Requested Time:

4:00 p.m., Eastern Standard Time

Ladies and Gentlemen:

Pursuant to Rule 460 under the Securities Act of 1933, as amended (the “Securities Act”), we, the representatives of the underwriters (the “Representatives”), wish to advise you that between December 2, 2019 and the date hereof, we have distributed approximately 3,601 copies of the Preliminary Prospectus of Bill.com Holdings, Inc., a Delaware corporation (the “Registrant”), dated December 2, 2019, to underwriters, dealers, institutional investors and others.

We, the undersigned Representatives, have and will, and have been informed by the participating underwriters that they have and will, comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the proposed offering.

In accordance with Rule 461 of the Securities Act, we hereby join in the request of the Registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 4:00 p.m. Eastern Standard Time on December 11, 2019, or as soon thereafter as practicable. We, the undersigned Representatives, confirm that the underwriters are aware of their obligations under the Securities Act.

[Signature Page Follows]

Very truly yours,
Goldman Sachs & Co. LLC

Show Raw Text
CORRESP
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filename1.htm

CORRESP

 December 9, 2019

VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

Washington, DC 20549

Re:

Bill.com Holdings, Inc.

Registration Statement on Form S-1

File No. 333-234730

Acceleration Request

Requested Date:

December 11, 2019

Requested Time:

4:00 p.m., Eastern Standard Time

 Ladies and Gentlemen:

 Pursuant
to Rule 460 under the Securities Act of 1933, as amended (the “Securities Act”), we, the representatives of the underwriters (the “Representatives”), wish to advise you that between December 2,
2019 and the date hereof, we have distributed approximately 3,601 copies of the Preliminary Prospectus of Bill.com Holdings, Inc., a Delaware corporation (the “Registrant”), dated December 2, 2019, to underwriters,
dealers, institutional investors and others.

 We, the undersigned Representatives, have and will, and have been informed by the participating underwriters
that they have and will, comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the proposed offering.

In accordance with Rule 461 of the Securities Act, we hereby join in the request of the Registrant that the effectiveness of the above-captioned Registration
Statement, as amended, be accelerated to 4:00 p.m. Eastern Standard Time on December 11, 2019, or as soon thereafter as practicable. We, the undersigned Representatives, confirm that the underwriters are aware of their obligations under the
Securities Act.

 [Signature Page Follows]

Very truly yours,

 Goldman Sachs & Co. LLC

BofA Securities, Inc.

 Jefferies LLC

 As representatives of the several underwriters

listed in Schedule I to the Underwriting

 Agreement

Goldman Sachs & Co. LLC

By:

 /s/ Jeffrey M. Gido

Name:  Jeffrey M. Gido

Title:    Managing Director

BofA Securities, Inc.

By:

 /s/ Magdalena Heinrich

Name:  Magdalena Heinrich

Title:    Managing Director

Jefferies LLC

By:

 /s/ C. Cullom Davis

Name:  C. Cullom Davis

Title:    Vice Chairman

cc:
 John Rettig, Chief Financial Officer and Executive Vice President

Raj Aji, Esq., General Counsel, Chief Compliance Officer and Corporate Secretary

Bill.com Holdings, Inc.

James D. Evans, Esq.

 Mark C.
Stevens, Esq.

 Dawn H. Belt, Esq.

Nicolas H. R. Dumont, Esq.

Fenwick & West LLP

Raj S. Judge, Esq.

 Andrew D.
Hoffman, Esq.

 Wilson Sonsini Goodrich & Rosati, P.C.