May 10, 2013
VIA EDGAR AND TELECOPY
Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, DC 20549-4561
Attn: Mr. Mark P. Shuman
Re: | UBIC, Inc. (the “Company”) |
| Registration Statement on Form F-1 |
| File No. 333-184691 |
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, we, as representatives of the several underwriters, hereby request acceleration of the effective date of the above-referenced Registration Statement so that it will become effective at 4:00 p.m., Washington D.C. time, on Monday, May 13, 2013, or as soon thereafter as practicable.
The following is supplemental information supplied under Rule 418(a)(7) and Rule 460 under the Securities Act of 1933:
(i) | Date of preliminary prospectus: May 10, 2013 |
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(ii) | Dates of distribution: May 10, 2013 through May 13, 2013 |
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(iii) | Number of prospective underwriters and broker-dealers to whom the preliminary prospectus was furnished: |
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| · Underwriters: 4 |
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| · Broker-dealers: 3 |
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(iv) | Number of prospectuses so distributed: 702 |
The undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.
| Very truly yours, | |
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| MAXIM GROUP LLC | |
| THE BENCHMARK COMPANY, LLC | |
| As Representatives of the Underwriters | |
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| BY: MAXIM GROUP LLC | |
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| By: | /s/ Clifford Teller |
| Name: | Clifford Teller |
| Title: | Head of Investment Banking |