Avalara, Inc.
255 South King Street, Suite 1800
Seattle, Washington 98104
June 4, 2019
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549
Attention: | Jan Woo, Legal Branch Chief | |
Matthew Crispino, Staff Attorney |
Re: | Avalara, Inc. | |
Registration Statement on Form S-1 | ||
File No. 333-231930 |
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Avalara, Inc. (the “Registrant”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1, so that it may become effective at 5:00 p.m. Eastern Daylight Time on June 5, 2019, or as soon as practicable thereafter. The Registrant hereby authorizes each of Andrew B. Moore and Allison C. Handy, both of whom are attorneys with the Registrant’s outside legal counsel, Perkins Coie LLP, to orally modify or withdraw this request for acceleration.
We request that we be notified of such effectiveness by a telephone call to Mr. Moore at (206) 359-8649 or, in his absence, Ms. Handy at (206) 359-3295.
[Signature page follows]
| Respectfully submitted, |
/s/ Alesia L. Pinney |
| Alesia L. Pinney |
Executive Vice President, General Counsel, and Secretary |
cc: | Scott M. McFarlane | |
| William D. Ingram | ||
Avalara, Inc. | ||
| Andrew B. Moore | ||
| Allison C. Handy | ||
Perkins Coie LLP | ||
| John T. McKenna | ||
| Alan D. Hambelton | ||
Cooley LLP | ||
