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Alan Bickerstaff (512) 320-9229 Phone (512) 542-5219 Fax abickerstaff@andrewskurth.com |
October 17, 2013
B001
FOIA CONFIDENTIAL TREATMENT REQUESTED BY
MAVENIR SYSTEMS
VIA E-MAIL AND U.S. MAIL
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington D.C. 20549-4561
Mail Stop 4561
RE: | Mavenir Systems |
Registration Statement on Form S-1, File No. 333-191563
Initially Filed Publicly on October 4, 2013
CIK No. 0001361470
Ladies and Gentlemen:
Per our telephone conversation on October 11, 2013 with Mr. Evan Jacobson of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), we are submitting this letter on behalf of our client, Mavenir Systems (the “Company”), in connection with the above-referenced Registration Statement (the “Registration Statement”) to supplementally provide the Staff with a draft of the Company’s proposed disclosure regarding estimated financial results for the quarter ended September 30, 2013 (the “Recent Developments Disclosure”). The proposed Recent Developments Disclosure is attached hereto asExhibit A. The Company proposes to include this disclosure in an amendment to the Registration Statement to be filed shortly before the Company commences its road show for its initial public offering.
[***] indicates material that has been omitted pursuant to a Request for Confidential Treatment filed with the Securities and Exchange Commission. A complete copy of this letter, including redacted portions so indicated, has been filed separately with the Securities Exchange Commission.
CONFIDENTIAL TREATMENT REQUESTED BY MAVENIR SYSTEMS, INC.
Securities and Exchange Commission
Re: Mavenir Systems, Inc.
October 17, 2013
Page 2 |
B002
Rule 83 Request for Confidential Information
In accordance with Rule 83 of the Rules of practice of the Commission (17 C.F.R. § 200.83), we also request, for reasons of business confidentiality, that the Commission not disclose the Recent Development Disclosure, or the fact of the existence thereof, or this request, in response to any request under the Freedom of Information Act (5 U.S.C § 552) or otherwise. Please promptly inform the undersigned of any request for the Recent Developments Disclosure made pursuant to the Freedom of Information Act or otherwise so that we may substantiate the foregoing request for confidential treatment in accordance with Rule 83.
Pursuant to Rule 83, a copy of this request (but not the Recent Developments Disclosure) is also being delivered to the Freedom of Information Act Officer of the Commission.
Please direct your questions or comments regarding this letter to the undersigned by telephone at (512) 320-9229. Thank you for your assistance.
Respectfully submitted, |
Andrews Kurth LLP |
/s/ Alan Bickerstaff |
Alan Bickerstaff |
CONFIDENTIAL TREATMENT REQUESTED BY MAVENIR SYSTEMS, INC.
B003
EXHIBIT A
RECENT DEVELOPMENTS
Recent Developments
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[***] Portions of this page have been omitted pursuant to a request for confidential treatment and filed separately with the Securities and Exchange Commission.