Simpson Thacher & Bartlett LLP
425 LEXINGTON AVENUE
NEW YORK, NY 10017-3954
TELEPHONE: +1-212-455-2000
FACSIMILE: +1-212-455-2502
Direct Dial Number +1-212-455-2812 |
E-mail Address rfenyes@stblaw.com |
| VIA EDGAR | November 10, 2020 |
| Re: | Acceleration Request for Bentley Systems, Incorporated Registration Statement on Form S-1 (File No. 333-250002) |
Division of Corporation Finance
Office of Technology
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
c/o Jeffrey Kauten
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, we attach the requests of our client, Bentley Systems, Incorporated, and of the underwriters that effectiveness of the above-referenced Registration Statement be accelerated to 4:00 p.m., New York, NY time, on November 12, 2020, or as soon as practicable thereafter. We ask, however, that the Securities and Exchange Commission staff not accelerate such effectiveness until we speak with you on that date.
Please call me at (212) 455-2812 with any questions.
| Very Truly yours, | |
| /s/ Richard A. Fenyes | |
| Richard A. Fenyes |
| cc: | Bentley Systems, Incorporated |
Gregory S. Bentley
David J. Hollister
David R. Shaman
Goodwin Procter LLP
Richard A. Kline
Sarah B. Axtell
November 10, 2020
VIA EDGAR
| Re: | Bentley Systems, Incorporated |
Registration Statement on Form S-1
File No. 333-250002
Division of Corporation Finance
Office of Technology
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
c/o Jeffrey Kauten
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Bentley Systems, Incorporated (the “Company”) hereby requests that the effective date of the above-referenced Registration Statement be accelerated so that it may become effective at 4:00 p.m., New York, NY time, on November 12, 2020, or as soon as possible thereafter. In this regard, the Company is aware of its obligations under the Securities Act.
[Signature Page Follows]
| Very truly yours, | ||
| BENTLEY SYSTEMS, INCORPORATED | ||
| By: | /s/ David R. Shaman | |
| Name: David R. Shaman | ||
| Title: Chief Legal Officer and Corporate Secretary | ||