0001437749-19-023395.txt : 20191223 0001437749-19-023395.hdr.sgml : 20191223 20191122111943 ACCESSION NUMBER: 0001437749-19-023395 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20191122 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VIVEVE MEDICAL, INC. CENTRAL INDEX KEY: 0000879682 STANDARD INDUSTRIAL CLASSIFICATION: ELECTROMEDICAL & ELECTROTHERAPEUTIC APPARATUS [3845] IRS NUMBER: 043153858 STATE OF INCORPORATION: B0 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 345 INVERNESS DRIVE SOUTH STREET 2: BUILDING B, SUITE 250 CITY: ENGLEWOOD STATE: CO ZIP: 80112 BUSINESS PHONE: 4085301900 MAIL ADDRESS: STREET 1: 345 INVERNESS DRIVE SOUTH STREET 2: BUILDING B, SUITE 250 CITY: ENGLEWOOD STATE: CO ZIP: 80112 FORMER COMPANY: FORMER CONFORMED NAME: PLC SYSTEMS INC DATE OF NAME CHANGE: 19930328 CORRESP 1 filename1.htm vive20191121c_corresp.htm

 

Viveve Medical, Inc.

345 Inverness Drive South

Building B, Suite 250

Englewood, CO 80112

 

 

VIA EDGAR

 

November 22, 2019

 

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention: Tim Buchmiller, Senior Attorney

 

Re:

Viveve Medical, Inc.
Acceleration Request for Registration Statement on Form S-1
File No. 333-233639

 

Dear Mr. Buchmiller:

 

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Viveve Medical, Inc. (the “Company”) hereby requests that the effective date and time of the above-referenced registration statement (the “Registration Statement”) be accelerated to November 22, 2019 at 11:30 a.m., Eastern Time, or at such later time as the Company or its counsel, Goodwin Procter LLP, may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”). Once the Registration Statement is effective, please orally confirm the event with our counsel, Goodwin Procter LLP, by calling Bradley A. Bugdanowitz at (415) 733-6099. 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: Bradley A. Bugdanowitz, by facsimile to (415) 520-9513 or by email to bbugdanowitz@goodwinlaw.com.

 

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 Bradley A. Bugdanowitz of Goodwin Procter LLP at (415) 733-6099.

 

 
 

 

 

Sincerely,

 

 

VIVEVE MEDICAL, Inc. 

 

 

/s/ Scott Durbin                          

Scott Durbin
Chief Executive Officer

 

 

cc:

Jim Robbins (Viveve Medical, Inc.)

 

Mitchell S. Bloom (Goodwin Procter LLP)

 

Bradley A. Bugdanowitz (Goodwin Procter LLP)

 

Michael F. Nertney (Ellenoff Grossman & Schole LLP)