September 19, 2016
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549-3720
Attention: | Barbara C. Jacobs, Assistant Director | |
Bernard Nolan, Attorney-Advisor | ||
Stephen Krikorian, Accounting Branch Chief | ||
Juan Migone, Staff Accountant | ||
Re: | Apptio, Inc. | |
Registration Statement on Form S-1 | ||
(File No. 333-213334) |
Ladies and Gentlemen:
Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, as amended, we wish to advise that between September 12, 2016 and the date hereof, approximately 6,172 copies of the Preliminary Prospectus dated September 12, 2016 were distributed to prospective underwriters, institutional investors and prospective dealers in connection with the above-captioned Registration Statement.
We wish to advise you that the participating underwriters have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 4:00 p.m. Eastern Daylight Time, on Thursday, September 22, 2016, or as soon thereafter as practicable, or at such later time as Apptio, Inc. or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission.
[signature page follows]
Very truly yours,
Goldman, Sachs & Co.,
J.P. Morgan Securities LLC and
Merrill Lynch, Pierce, Fenner & Smith
Incorporated
As representatives of the several Underwriters
By: | Goldman, Sachs & Co. | |
By: | /s/ Matt Leavitt | |
Name: Matt Leavitt | ||
Title: Managing Director |
By: | J.P. Morgan Securities LLC | |
By: | /s/ Curt Sigfstead | |
Name: Curt Sigfstead | ||
Title: Managing Director |
By: | Merrill Lynch, Pierce, Fenner & Smith Incorporated | |
By: | /s/ Michael Liloia | |
Name: Michael Liloia | ||
Title: Vice-President |