MERU NETWORKS, INC.
894 Ross Drive
Sunnyvale, California 94089
(408) 215-5300
November 7, 2012
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Ryan Houseal, Attorney-Advisor
Katherine Wray, Attorney-Advisor
Re: Meru Networks, Inc. Registration Statement on Form S-3 originally filed September 5, 2012, as amended (Registration No. 333-183726)
Acceleration Request
Requested Date: November 8, 2012
Requested Time: 4:00 p.m. Eastern Time
Ladies and Gentlemen:
Meru Networks, Inc. (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to make the above-captioned Registration Statement on Form S-3 effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable.
The Registrant hereby acknowledges that:
· should the Commission or 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 Registrant 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.
| Sincerely, |
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| MERU NETWORKS, INC. |
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| By: | /s/ Brett T. White |
| | Brett T. White |
| | Chief Financial Officer |
Cc Richard Mosher, Esq., Meru Networks, Inc.
David A. Bell, Esq., Fenwick & West LLP