July 22, 2015
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attn: | Mr. Craig D. Wilson, Sr. Asst. Chief Accountant |
Ms. Megan Akst, Senior Staff Accountant
Ms. Melissa Kindelan, Senior Staff Accountant
| RE: | BroadSoft, Inc. |
Form 10-K for the Fiscal Year Ended December 31, 2014
Filed February 25, 2015
File No. 001-34777
Dear Mr. Wilson:
BroadSoft, Inc. (the“Company”)hereby acknowledges that 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 8, 2015 with respect to the above-referenced filing (the“Comments”).Contemporaneously herewith, the Company’s outside counsel, Cooley LLP, is submitting a response letter addressing the Comments to the Staff via EDGAR.
Pursuant to the Staff’s letter, the Company further acknowledges that:
| • | the Company 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 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. |
| Very truly yours, | ||
| BROADSOFT, INC. | ||
| By: | /s/ James A. Tholen | |
| James A. Tholen | ||
| Chief Financial Officer | ||
| cc: | Mary Ellen Seravalli, BroadSoft, Inc. |
Darren K. DeStefano, Cooley LLP
