iPass Inc.
3800 Bridge Parkway
Redwood Shores, CA 94065
(650) 232-4100
September 18, 2017
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attn: | Ji Shin, Attorney-Advisor |
| Jan Woo, Legal Branch Chief, Office of Information Technologies and Services |
| RE: | iPass Inc. |
| Registration Statement on Form S-3 |
| File No. 333-220279 |
Ladies and Gentlemen:
iPass Inc. hereby requests that the Securities and Exchange Commission take appropriate action to cause the above-referenced Registration Statement on Form S-3 to become effective on September 21, 2017, at 4:00 p.m., Eastern Time, or as soon thereafter as is practicable.
| Very truly yours, | ||
| iPass Inc. | ||
| By: | /s/ Darin Vickery | |
| Darin Vickery | ||
| Chief Financial Officer | ||