Switch, Inc.
7135 S. Decatur Boulevard
Las Vegas, NV 89118
October 4, 2017
VIA EDGAR TRANSMISSION
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
Attention: | Barbara C. Jacobs; Bernard Nolan; Craig Wilson; Morgan Youngwood | |
Re: | Switch, Inc. | |
Registration Statement on FormS-1 (RegistrationNo. 333-220405) |
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on FormS-1, as amended (FileNo. 333-220405) (the “Registration Statement”) of Switch, Inc. (the “Company”). We respectfully request that the Registration Statement become effective as of 4:30 p.m., Eastern Time, on October 5, 2017, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Shayne Kennedy at (714)755-8181.
The Company acknowledges the following:
• | 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 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. |
Thank you for your assistance in this matter.
Very truly yours, | ||
Switch, Inc. | ||
By: | /s/ Thomas Morton | |
Thomas Morton | ||
President and General Counsel |
cc: | Rob Roy, Chief Executive Officer, Switch, Inc. |
Chase Leavitt, Esq., Deputy General Counsel, Switch, Ltd.
Charles K. Ruck, Latham & Watkins LLP
Shayne Kennedy, Latham & Watkins LLP
Kenneth J. Gordon, Goodwin Procter LLP
Richard A. Kline, Goodwin Procter LLP
Seo Salimi, Goodwin Procter LLP