September 3, 2010
VIA EDGAR AND FACSIMILE
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Ms. Maryse Mills-Apenteng
| Re: | Sonic Solutions (the “Company”) |
| Registration Statement on Form S-4 (File No. 333-168076) (the “Registration Statement”) |
ACCELERATION REQUEST
REQUESTED DATE: September 7, 2010
REQUESTED TIME: 9:00 AM, EASTERN TIME
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the Company requests that the above-referenced Registration Statement be declared effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable or at such later time as the Company may request by telephone to the Securities and Exchange Commission (the “Commission”). The Company hereby authorizes both James R. Tanenbaum and Nilene R. Evans of Morrison & Foerster LLP, counsel for the Company, to make such request on our behalf.
In connection with the acceleration request, the Company hereby acknowledges that:
| • | should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
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SONIC SOLUTIONS
HEADQUARTERS
7250 Redwood Boulevard, Suite 300, Novato, CA 94945, USA
Tel: +1.415.893.8000 | Fax: +1.415.893.7011
WWW.SONIC.COM
Ms. Maryse Mills-Apenteng
Securities and Exchange Commission
Page 2
| Sincerely, | ||||
| SONIC SOLUTIONS | ||||
| By: | /s/ David C. Habiger | |||
| Name: | David C. Habiger | |||
| Title: | President and Chief Executive Officer | |||
cc:
James R. Tanenbaum
Nilene R. Evans
Morrison & Foerster LLP