April 29, 2011
VIA EDGAR AND COURIER
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attention: |
Larry Spirgel |
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Kathleen Krebs |
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Re: |
Boingo Wireless, Inc. |
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Amendment No. 5 to Registration Statement on Form S-1 |
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File No. 333-171719 |
Ladies and Gentlemen:
Boingo Wireless, Inc. (the Company) has electronically transmitted Amendment No. 5 to the Registration Statement on Form S-1, together with certain exhibits thereto, in connection with the Companys initial public offering. A manually executed signature page has been executed prior to the time of the electronic filing and will be retained by the Company for five years. We have also enclosed with the couriered delivery of this letter (i) three unmarked hard copies of Amendment No. 5, and (ii) three hard copies of Amendment No. 5 which are marked to show changes to the Registration Statement filed on January 14, 2011, as amended April 18, 2011.
Amendment No. 5 has been filed to incorporate the information contained in its recently filed free writing prospectus and to correct certain typographical errors.
Very truly yours,
GUNDERSON DETTMER STOUGH |
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VILLENEUVE FRANKLIN & HACHIGIAN, LLP |
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By: |
/s/ Ilan Lovinsky |
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Ilan Lovinsky |
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GUNDERSON DETTMER STOUGH VILLENEUVE FRANKLIN & HACHIGIAN, LLP
11682 EL CAMINO REAL, SUITE 100, SAN DIEGO, CA 92130 / PHONE: 858.436.8000 / FAX: 877.881.9192
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