SEC Company Response from BILL Holdings, (BILL) — Dec 9, 2019
BILL Holdings, Inc.
Date: Dec. 9, 2019 · CIK: 0001786352 · Accession: 0001193125-19-309254
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File numbers found in text: 333-234730
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CORRESP 1 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.