BANK OF COMMERCE HOLDINGS
November 15, 2018
VIA EDGAR
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attention: David Gessert, Staff Attorney
Re: | Bank of Commerce Holdings |
Dear Mr. Gessert:
In accordance with Rule 461 under the Securities Act of 1933, as amended, Bank of Commerce Holdings (the “Company”) hereby respectfully requests acceleration of the effectiveness of the Company’s Registration Statement on Form S-4 filed on November 7, 2018 (File No. 333-228243) as amended on November 15, 2018 (the “Registration Statement”) so that the Registration Statement shall become effective at 5:00 p.m. Eastern Time on November 19, 2018, or as soon as possible thereafter.
We would appreciate notification by telephone of the effective date of the Registration Statement and confirmation of such effectiveness in writing.
If you should have any questions about the foregoing request, please contact our counsel, Mr. Stephen M. Klein of Miller Nash Graham & Dunn LLP, at (206) 777-7506, or the undersigned at (916) 677-5800. Thank you for your cooperation in this matter.
| Very truly yours,
BANK OF COMMERCE HOLDINGS |
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| By: | /s/ Randall S. Eslick |
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| Randall S. Eslick |
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cc: Stephen M. Klein, Miller Nash Graham & Dunn LLP