Viveve Medical, Inc.
345 Inverness Drive South
Building B, Suite 250
Englewood, CO 80112
VIA EDGAR
January 13, 2021
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences
100 F Street, N.E.
Washington, DC 20549
Attention: Alan Campbell
Re: | Viveve Medical, Inc. Acceleration Request for Registration Statement on Form S-1 Filed December 18, 2020 File No. 333-251517 |
Dear Mr. Campbell:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Viveve Medical, Inc. (the “Company”) hereby requests that the effective date and time of the above-referenced registration statement (the “Registration Statement”) be accelerated to January 13, 2021 at 5:00 p.m., Eastern Time, or at such later time as the Company or its counsel, Goodwin Procter LLP, may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”). Once the Registration Statement is effective, please orally confirm the event with our counsel, Goodwin Procter LLP, by calling Heidi Mayon at (650) 752-3227. We also respectfully request that a copy of the written order from the Commission verifying the effective time and date of the Registration Statement be sent to our counsel, Goodwin Procter LLP, Attention: Heidi Mayon, by facsimile to (650) 471-6055 or by email to HMayon@goodwinlaw.com.
In connection with the foregoing, the Company hereby acknowledges the following:
| ● | should the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; |
| ● | the action of the Commission or the staff of the Commission, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and |
| ● | the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
If you have any questions regarding this request, please contact Heidi Mayon of Goodwin Procter LLP at (650) 752-3227.
| Sincerely, VIVEVE MEDICAL, Inc. /s/ Scott Durbin Scott Durbin Chief Executive Officer |
cc: | Jim Robbins (Viveve Medical, Inc.) |
| Mitchell S. Bloom (Goodwin Procter LLP) |
| Heidi Mayon (Goodwin Procter LLP) Wendy Grasso (Reed Smith LLP) |
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