Critical Path, Inc.
42-47 Lower Mount Street
Dublin 2, Ireland
February 19, 2008
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Critical Path, Inc. |
Schedule 13E-3 Initially Filed on December 26, 2007 (File No. 000-25331)
Schedule 14A Initially Filed on December 26, 2007 (File No. 005-56169)
Ladies and Gentlemen:
In connection with the above-referenced filings, Critical Path, Inc. (the “filing person”) hereby acknowledges to the U.S. Securities and Exchange Commission (the “Commission”) that:
• | the filing person is responsible for the adequacy and accuracy of the disclosure in the filing; |
• | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
• | the filing person may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please direct any questions with respect to the foregoing to Gregg Vignos at (415) 856-7210.
Sincerely, |
/s/ Mark Palomba |
Mark Palomba |
Chief Executive Officer |
PETER KELLNER
RICHMOND CP LLC
c/o Richmond Management LLC
645 Madison Avenue, 20th Floor
New York, New York 10022
January 28, 2008
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Critical Path, Inc. |
Schedule 13E-3 Initially Filed on December 26, 2007 (File No. 000-25331)
Schedule 14A Initially Filed on December 26, 2007 (File No. 005-56169)
Ladies and Gentlemen:
In connection with the above-referenced filings, Peter Kellner and Richmond CP LLC (the “filing persons”) hereby acknowledge to the U.S. Securities and Exchange Commission (the “Commission”) that:
• | the filing persons are responsible for the adequacy and accuracy of the disclosure in the filing; |
• | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
• | the filing persons may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please direct any questions with respect to the foregoing to Adam M. Fox, Esq. of Dechert LLP at (212) 649-8732.
Sincerely, |
/s/ Peter B. Kellner |
Peter Kellner |
Individually and as Managing Member of Richmond CP LLC
Campina Enterprises Limited
7th Floor, Cheung Kong Center
2 Queen’s Road Central
Hong Kong
February 18, 2008
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Critical Path, Inc. |
Schedule 13E-3 Initially Filed on December 26, 2007 (File No. 000-25331)
Ladies and Gentlemen:
In connection with the above-referenced filing, Campina Enterprises Limited (the “filing person”) hereby acknowledges to the U.S. Securities and Exchange Commission (the “Commission”) that:
• | the filing person is responsible for the adequacy and accuracy of the disclosure in the filing; |
• | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
• | the filing person may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please direct any questions with respect to the foregoing to Eirene Yeung or Erica Tse at 852-2128-8888.
Sincerely, |
/s/ Ip Tak Chuen Edmond |
Ip Tak Chuen Edmond |
Director |
Cenwell Limited
22nd Floor, Hutchison House
10 Harcourt Road
Hong Kong
February 18, 2008
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Critical Path, Inc. |
Schedule 13E-3 Initially Filed on December 26, 2007 (File No. 000-25331)
Ladies and Gentlemen:
In connection with the above-referenced filing, Cenwell Limited (the “filing person”) hereby acknowledges to the U.S. Securities and Exchange Commission (the “Commission”) that:
• | the filing person is responsible for the adequacy and accuracy of the disclosure in the filing; |
• | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
• | the filing person may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please direct any questions with respect to the foregoing to Eirene Yeung or Erica Tse at 852-2128-8888.
Sincerely, |
/s/ Ip Tak Chuen Edmond |
Ip Tak Chuen Edmond |
Authorized Signatory |
Vectis-CP Holdings, LLC
c/o TPG Growth LLC
345 California Street, Suite 3300
San Francisco, CA 94104
February 19, 2008
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Critical Path, Inc. |
Schedule 13E-3 Initially Filed on December 26, 2007 (File No. 000-25331)
Schedule 14A Initially Filed on December 26, 2007 (File No. 005-56169)
Ladies and Gentlemen:
In connection with the above-referenced filings, Vectis-CP Holdings, LLC (the “filing person”) hereby acknowledges to the U.S. Securities and Exchange Commission (the “Commission”) that:
• | the filing person is responsible for the adequacy and accuracy of the disclosure in the filing; |
• | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
• | the filing person may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please direct any questions with respect to the foregoing to the undersigned at (415) 743-1610.
Sincerely, |
/s/ Matthew T. Hobart |
Matthew T. Hobart |
Managing Member of Vectis Group, LLC, as Managing Member of Vectis-CP Holdings, LLC
GENERAL ATLANTIC PARTNERS 74, L.P.
GAPSTAR, LLC
GAP COINVESTMENT PARTNERS II, L.P.
CP HOLDCO, LLC
CP MERGER CO.
c/o General Atlantic Service Company, LLC
3 Pickwick Plaza, Greenwich, CT 06830
&
GAPCO GMBH CO. & KG
c/o General Atlantic GmbH
Koenigsallee 62, 40212 Duesseldorf, Germany
February 19, 2008
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Critical Path, Inc. |
Schedule 13E-3 Initially Filed on December 26, 2007 (File No. 000-25331)
Schedule 14A Initially Filed on December 26, 2007 (File No. 005-56169)
Ladies and Gentlemen:
In connection with the above-referenced filings, General Atlantic Partners 74, L.P., GapStar, LLC, GAP Coinvestment Partners II, L.P., GAPCO GmbH Co. & KG, CP Holdco, LLC and CP Merger Co. (the “filing persons”) hereby acknowledge to the U.S. Securities and Exchange Commission (the “Commission”) that:
• | the filing persons are responsible for the adequacy and accuracy of the disclosure in the filing; |
• | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
• | the filing persons may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please direct any questions with respect to the foregoing to Douglas A. Cifu of Paul, Weiss, Rifkind, Wharton & Garrison LLP, the filing persons’ counsel, at (212) 373-3436.
Sincerely, | ||
GENERAL ATLANTIC PARTNERS 74, L.P. | ||
By: | General Atlantic LLC, Its general partner | |
By: | /s/ Matthew Nimetz | |
Name: | Matthew Nimetz | |
Title: | Managing Director | |
GAPSTAR, LLC | ||
By: | General Atlantic LLC, Its sole member | |
By: | /s/ Matthew Nimetz | |
Name: | Matthew Nimetz | |
Title: | Managing Director | |
GAP COINVESTMENT PARTNERS II, L.P. | ||
By: | /s/ Matthew Nimetz | |
Name: | Matthew Nimetz | |
Title: | A General Partner | |
GAPCO GMBH & CO. KG | ||
By: | GAPCO Management GmbH, Its general partner | |
By: | /s/ Matthew Nimetz | |
Name: | Matthew Nimetz | |
Title: | Managing Director |
CP HOLDCO, LLC | ||
By: | /s/ Tom C. Tinsley | |
Name: | Tom C. Tinsley | |
Title: | President | |
CP MERGER CO. | ||
By: | /s/ Tom C. Tinsley | |
Name: | Tom C. Tinsley | |
Title: | President |