CONVERSIONPOINT HOLDINGS, INC.
840 Newport Center Drive, Suite 450
Newport Beach, CA 926608
June 21, 2019
VIA EDGAR
Jan Woo, Esq.
Legal Branch Chief
Office of Information Technologies and Services
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | ConversionPoint Holdings, Inc. Registration Statement on Form S-1, as amended Filed April 30, 2019 File No. 333-230862 |
Dear Ms. Woo:
On behalf of ConversionPoint Holdings, Inc., a Delaware corporation (the “Company”), we hereby request, pursuant to Rule 477 of the Securities Act of 1933, as amended (“Securities Act”), that the Registration Statement on Form S-1, together with all exhibits and amendments thereto (File No. 333-230862), as initially filed with the Securities and Exchange Commission (“Commission”) onApril 15, 2019 and subsequently amended onApril 30, 2019 (“Registration Statement”) be withdrawn effective immediately. The Company is seeking withdrawal of the Registration Statement because of unfavorable market conditions. The Registration Statement has not been declared effective and none of the Company’s securities has been sold pursuant to the Registration Statement.
In accordance with Rule 457(p) of the Securities Act, the Company requests that all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use.
Should you have any questions regarding this request for withdrawal, please contact Larry Cerutti of Troutman Sanders LLP by telephone at (949) 622-2710.
Very truly yours,
ConversionPoint Holdings, Inc.
By:/s/ Robert Tallack Robert Tallack President and Chief Executive Officer |
