July 23, 2012
VIA EDGAR
Mr. Gabriel Eckstein
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
| | |
RE: | | BroadSoft, Inc. |
| | Form 10-K for the Fiscal Year Ended December 31, 2011 |
| | Filed February 29, 2012 |
| | Form 10-Q for the Quarterly Period Ended March 31, 2012 |
| | Filed May 7, 2012 |
| | File No. 001-34777 |
Dear Mr. Eckstein:
BroadSoft, Inc. (the “Company”) hereby acknowledges it has received comments from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) by letter dated July 16, 2012 with respect to the above-referenced filings (the “Comments”). The Company currently intends to respond to the Comments by August 13, 2012, after the preparation and filing of its Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2012.
Pursuant to the Staff’s letter, the Company further acknowledges:
| • | | the Company is responsible for the adequacy and accuracy of the disclosure in the filings; |
| • | | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and |
| • | | the Company 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. |
9737 Washingtonian Blvd, Suite 350— Gaithersburg, MD 20878— www.broadsoft.com
| | |
Very truly yours, |
|
BROADSOFT, INC. |
| |
By: | | /s/ James A. Tholen |
| | James A. Tholen |
| | Chief Financial Officer |
cc: | Darren K. DeStefano, Cooley LLP |
9737 Washingtonian Blvd, Suite 350— Gaithersburg, MD 20878— www.broadsoft.com