Letter to the SEC

-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, NUpe3jh42na9A31R4w6FS9ADMOXHZCIQALeQi0HyEJgI7aL4z8J6Ha6T+Zc71Qqb itd2ur7ssx7/t2bRjPKHRw== 0001193125-05-126472.txt : 20060602 0001193125-05-126472.hdr.sgml : 20060602 20050616163242 ACCESSION NUMBER: 0001193125-05-126472 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050616 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BOTTOMLINE TECHNOLOGIES INC /DE/ CENTRAL INDEX KEY: 0001073349 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-PREPACKAGED SOFTWARE [7372] IRS NUMBER: 020433924 STATE OF INCORPORATION: DE FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 325 CORPORATE DRIVE CITY: PORTSMOUTH STATE: NH ZIP: 03801 BUSINESS PHONE: 6034360700 MAIL ADDRESS: STREET 1: 325 CORPORATE DRIVE CITY: PORTSMOUTH STATE: NH ZIP: 03801 CORRESP 1 filename1.htm Letter to the SEC

Bottomline Technologies (de), Inc.

325 Corporate Drive

Portsmouth, New Hampshire 03801

June 16, 2005

By EDGAR and Facsimile

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Daniel Lee, Esq.

Re:	Bottomline Technologies (de), Inc.

Registration Statement on Form S-3

File No. 333-122906

Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Bottomline Technologies (de), Inc. (the “Registrant”) hereby requests acceleration of the effective date of the above-referenced registration statement (the “Registration Statement”), so that it may become effective at 5 p.m., Eastern time, on June 17, 2005, or as soon thereafter as practicable.

As requested in a letter dated March 4, 2005 from Barbara Jacobs of the staff of the Securities and Exchange Commission (the “Commission”), the Registrant hereby acknowledges that:

(i)

should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

(ii)

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(iii)

the Registrant may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you require any additional information, please do not hesitate to contact me at 603-436-0700 or Jessica Semerjian of Wilmer Cutler Pickering Hale and Dorr LLP at 202-663-6886.


Sincerely, BOTTOMLINE TECHNOLOGIES (de), INC.

By:		/s/ Kevin Donovan
		Kevin Donovan Chief Financial Officer

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