SEC Comment Letter 0000000000-25-002129 to Aspen Technology, Inc. (CIK 0001897982)
Aspen Technology, Inc. (CIK 0001897982)
Date: Feb. 24, 2025 · CIK: 0001897982 · Accession: 0000000000-25-002129
AI Filing Summary & Sentiment
Letter
February 24, 2025 Antonio J. Pietri President and Chief Executive Officer Aspen Technology, Inc. 20 Crosby Drive Bedford, MA 01730 Re:Aspen Technology, Inc. Schedule 14D-9/A filed February 24, 2025 Schedule 13E-3/A filed February 24, 2025 File No. 005-93677 Dear Antonio J. Pietri: We have reviewed your filing and have the following comment. Please respond to this comment by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Schedule 13E-3/A filed February 24, 2025 General 1.We note that each of Exhibits (c)(6), (c)(7), and (c)(8) to the Schedule 13E-3 has been filed with the same corresponding note: "Certain portions of this exhibit have been redacted and provided separately to the Securities and Exchange Commission pursuant to a request for confidential treatment." We have not yet received any such request for confidential treatment. Please submit such request promptly, or advise.
We remind you that the filing persons are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
February 24, 2025 Page 2
Please direct any questions to Brian Soares at 202-551-3690. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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February 24, 2025
Antonio J. Pietri
President and Chief Executive Officer
Aspen Technology, Inc.
20 Crosby Drive
Bedford, MA 01730
Re:Aspen Technology, Inc.
Schedule 14D-9/A filed February 24, 2025
Schedule 13E-3/A filed February 24, 2025
File No. 005-93677
Dear Antonio J. Pietri:
We have reviewed your filing and have the following comment.
Please respond to this comment by providing the requested information or advise us
as soon as possible when you will respond. If you do not believe our comment applies to your
facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Schedule 13E-3/A filed February 24, 2025
General
1.We note that each of Exhibits (c)(6), (c)(7), and (c)(8) to the Schedule 13E-3 has been
filed with the same corresponding note: "Certain portions of this exhibit have been
redacted and provided separately to the Securities and Exchange Commission
pursuant to a request for confidential treatment." We have not yet received any such
request for confidential treatment. Please submit such request promptly, or advise.
We remind you that the filing persons are responsible for the accuracy and adequacy
of their disclosures, notwithstanding any review, comments, action or absence of action by
the staff.
February 24, 2025
Page 2
Please direct any questions to Brian Soares at 202-551-3690.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions