Spotify Technology S.A.
42-44, avenue de la Gare
L-1610 Luxembourg
Grand Duchy of Luxembourg
March 20, 2018
VIA EDGAR
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 3561
100 F Street, N.E.
Washington, D.C. 20549
Attention: Lisa Etheredge, Robert S. Littlepage, Joshua Shainess, and Celeste M. Murphy
Spotify Technology S.A.
Registration Statement on
Form F-1 (File No. 333-223300)
Ladies and Gentlemen:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned registration statement on Form F-1 (the “Registration Statement”) relating to the registration of 55,731,480 ordinary shares, par value €0.000625 per share, of Spotify Technology S.A. (the “Company”), be accelerated to March 22, 2018 at 9:00 a.m. E.D.T. or as soon thereafter as may be practicable. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Gregory P. Rodgers at (212) 906-2918.
We understand that the staff of the Securities and Exchange Commission will consider this request as confirmation by the Company that it is aware of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Gregory P. Rodgers of Latham & Watkins LLP at the number set forth above. Thank you for your assistance in this matter.
*****
Sincerely, |
/s/ Horacio Gutierrez |
Horacio Gutierrez |
General Counsel |
Enclosures
cc: | (via email) |
Marc D. Jaffe, Latham & Watkins LLP |
Gregory P. Rodgers, Latham & Watkins LLP |
Benjamin Cohen, Latham & Watkins LLP |