INTERNET PATENTS CORPORATIOn
101 Parkshore Drive, Suite 100
Folsom, California 95630
February 11, 2015
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re: | Internet Patents Corporation |
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Internet Patents Corporation (the “Company”) hereby requests that its Registration Statement on Form S-4 (File No. 333-201323) be declared effective at noon, Washington, D.C. time, on February 12, 2015, or as soon thereafter as practicable.
In connection with this request, the Company acknowledges that:
| ● | should the Securities and Exchange Commission (the “Commission”) or the Commission’s staff (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| ● | the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| ● | the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
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| Very truly yours, | ||
| INTERNET PATENTS CORPORATION | |||
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| By: |
| /s/ L. Eric Loewe |
| Name: | L. Eric Loewe | |
| Title: | General Counsel and Secretary | |
