CORRESP

0001193125-13-051495.txt : 20130507 0001193125-13-051495.hdr.sgml : 20130507 20130212152956 ACCESSION NUMBER: 0001193125-13-051495 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20130212 FILER: COMPANY DATA: COMPANY CONFORMED NAME: XOOM Corp CENTRAL INDEX KEY: 0001315657 STANDARD INDUSTRIAL CLASSIFICATION: FUNCTIONS RELATED TO DEPOSITORY BANKING, NEC [6099] IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 BUSH STREET SUITE 300 CITY: SAN FRANCISCO STATE: CA ZIP: 94104 BUSINESS PHONE: 415-395-4203 MAIL ADDRESS: STREET 1: 100 BUSH STREET SUITE 300 CITY: SAN FRANCISCO STATE: CA ZIP: 94104 FORMER COMPANY: FORMER CONFORMED NAME: XOOM CORP DATE OF NAME CHANGE: 20050127 CORRESP 1 filename1.htm CORRESP

Xoom Corporation

100 Bush Street, Suite 300

San Francisco, CA 94104

VIA EDGAR AND FACSIMILE

February 12, 2013

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549-4720

Attention: Todd K. Schiffman, Assistant Director

Re:

Xoom Corporation

Acceleration Request for Registration Statement on Form S-1

File No. 333-185967

Dear Mr. Schiffman:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Xoom Corporation (the “Company”) hereby requests that the effective date of the above-referenced registration statement (the “Registration Statement”) be accelerated to February 14, 2013, at 4:00 p.m., Eastern Time, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”). In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act. Once the Registration Statement is effective, please orally confirm the event with our counsel, Goodwin Procter LLP, by calling Rick Kline at (650) 752-3139. We also respectfully request that a copy of the written order from the Commission verifying the effective time and date of the Registration Statement be sent to our counsel, Goodwin Procter LLP, Attention: Rick Kline, by facsimile to (650) 853-1038.

In connection with the foregoing, the Company hereby acknowledges the following:

•

should the Commission or the staff of the Commission, 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;

•

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

•

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any questions regarding this request, please contact Rick Kline of Goodwin Procter LLP at (650) 752-3139.

Sincerely,

XOOM CORPORATION

/s/ Christopher Ferro

Christopher Ferro

Vice President & General Counsel

cc:	John Kunze, President and Chief Executive Officer (Xoom Corporation)

Anthony McCusker, Partner (Goodwin Procter LLP)

Richard A. Kline, Partner (Goodwin Procter LLP)

Douglas D. Smith, Partner (Gibson, Dunn & Crutcher LLP)

Stewart L. McDowell, Partner (Gibson, Dunn & Crutcher LLP)