Bill.com Holdings, Inc.
1810 Embarcadero Road
Palo Alto, California 94303
December 9, 2019
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
| Attention: | Kathleen Krebs, Special Counsel Jeff Kauten, Staff Attorney Christine Dietz, Senior Staff Accountant Eiko Yaoita Pyles, Staff Accountant | |
| Re: | Bill.com Holdings, Inc. Registration Statement on Form S-1 (File No. 333-234730) originally filed November 15, 2019, as amended, and corresponding Registration Statement on Form 8-A (File No. 001-39149) filed December 3, 2019 | |
Requested Date: December 11, 2019
Requested Time: 4:00 PM Eastern Time
Ladies and Gentlemen:
Bill.com Holdings, 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 James D. Evans or Nicolas H. R. Dumont, 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. Evans at (206) 389-4559 or, in his absence, Mr. Dumont at (212) 430-2679.
* * *
| Sincerely, | ||
| BILL.COM HOLDINGS, INC. | ||
| By: | /s/ Raj Aji | |
| Raj Aji | ||
General Counsel, Chief Compliance Officer and Secretary | ||
| cc: | René Lacerte, President and Chief Executive Officer |
John Rettig, Chief Financial Officer and Executive Vice President, Finance and Operations
Bill.com Holdings, Inc.
Mark C. Stevens, Esq.
James D. Evans, Esq.
Dawn H. Belt, Esq.
Nicolas H.R. Dumont, Esq.
Fenwick & West LLP
[Signature Page to Company Acceleration Request Letter]
