BENEFITFOCUS, INC.
100 Benefitfocus Way
Charleston, SC 29492
June 29, 2020
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: | Matthew Crispino |
Jan Woo
Division of Corporation Finance
Office of Technology
Re: | Acceleration Request |
Benefitfocus, Inc.
Registration Statement on Form S-3
Filed June 24, 2020
(File No. 333-239406)
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the Act), Benefitfocus, Inc. (the Registrant) hereby requests that the U.S. Securities and Exchange Commission (the Commission) take appropriate action to accelerate the effective date of the above-referenced registration statement (the Registration Statement) so as to become effective on Wednesday, July 1, 2020, at 4:05 p.m. Eastern Time, or as soon thereafter as practicable.
The Registrant understands that the Commission will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that the Registrant is aware of its responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration Statement.
The Registrant respectfully requests that its legal counsel be notified when this request for acceleration has been granted by contacting via telephone call or email, Andrew J. Gibbons (Tel: 919-786-4038; E-mail: agibbons@wyrick.com). We also respectfully request that a copy of the written order from the Commission verifying the effective date and time of the Registration Statement be sent to Mr. Gibbons via email at agibbons@wyrick.com.
By: | /s/ Stephen M. Swad | |
Stephen M. Swad, Chief Financial Officer |
cc: Andrew J. Gibbons, Wyrick Robbins Yates & Ponton LLP