0001140361-14-042705.txt : 20160308 0001140361-14-042705.hdr.sgml : 20160308 20141118172103 ACCESSION NUMBER: 0001140361-14-042705 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20141118 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CollabRx, Inc. CENTRAL INDEX KEY: 0000931059 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-COMPUTER PROCESSING & DATA PREPARATION [7374] IRS NUMBER: 680370244 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 400 S. AUSTRALIAN AVENUE, SUITE 800 CITY: WEST PALM BEACH STATE: FL ZIP: 33401 BUSINESS PHONE: 561-855-1626 MAIL ADDRESS: STREET 1: 400 S. AUSTRALIAN AVENUE, SUITE 800 CITY: WEST PALM BEACH STATE: FL ZIP: 33401 FORMER COMPANY: FORMER CONFORMED NAME: CollabRx, Inc. DATE OF NAME CHANGE: 20120926 FORMER COMPANY: FORMER CONFORMED NAME: TEGAL CORP /DE/ DATE OF NAME CHANGE: 19950918 CORRESP 1 filename1.htm

COLLABRX, INC.
44 Montgomery Street, Suite 800
San Francisco, California  94104


November 18, 2014

By EDGAR Transmission

United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention:  Gabriel Eckstein

Re: CollabRx, Inc.:  Registration Statement on Form S-1 (File No. 333-199477)

Ladies and Gentlemen:

In accordance with Rule 461 of the General Rules and Regulations of the Securities Act of 1933, as amended (the “Securities Act”), CollabRx, Inc. (the “Company”) hereby respectfully requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 so that it may be declared effective at 5 p.m. (Washington, DC time), November 20, 2014, or as soon as practicable thereafter.

The Company hereby acknowledges the following:

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

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


(Remainder of Page Intentionally Left Blank)



If you have any questions regarding this request, please contact William Davisson of Goodwin Procter LLP at (650) 752-3114.

 
Sincerely,
     
 
COLLABRX, INC.
     
     
 
By:
/s/ Thomas R. Mika
 
Name:  Thomas R. Mika
Title:  President & Chief Executive Officer


cc:            William Davisson, Esq.
 
 
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