Zuora, Inc.
3050 South Delaware Street, Suite 301
San Mateo, California 94403
April 9, 2018
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
| Attention: | Barbara C. Jacobs, Assistant Director Matthew Derby, Staff Attorney Kathleen Collins, Accounting Branch Chief Rebekah Lindsey, Staff Accountant | |
| Re: | Zuora, Inc. Registration Statement on FormS-1 (FileNo. 333-223722) originally filed March 16, 2018, as amended, and corresponding Registration Statement on Form8-A (FileNo. 001-38451) filed April 5, 2018 | |
Requested Date: April 11, 2018
Requested Time: 4:00 PM Eastern Time
Ladies and Gentlemen:
Zuora, Inc. (the “Registrant”) hereby requests that the Securities and Exchange Commission take appropriate action to declare the above-captioned Registration Statements on Form S-1 and Form 8-A effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable.
The Registrant hereby authorizes Jeffrey R. Vetter or Ran D. Ben-Tzur, both of whom are attorneys with the Registrant’s outside legal counsel, Fenwick & West LLP, to orally modify or withdraw this request for acceleration.
The Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Vetter at (650)335-7631 or, in his absence, Mr. Ben-Tzur at (650)335-7613.
* * *
| Sincerely, | ||
| ZUORA, INC. | ||
| By: | /s/ Jennifer W. Pileggi | |
| Jennifer W. Pileggi | ||
| Senior Vice President, General Counsel, and Corporate Secretary | ||
| cc: | Tyler Sloat, Chief Financial Officer |
| Jennifer W. Pileggi, Esq., Senior Vice President, General Counsel and Corporate Secretary |
| Zuora, Inc. |
| Gordon K. Davidson, Esq. |
| Jeffrey R. Vetter, Esq. |
| Ran D. Ben-Tzur, Esq. |
| Fenwick & West LLP |
[Signature Page to Company Acceleration Request Letter]
