0000921895-18-003192.txt : 20190221 0000921895-18-003192.hdr.sgml : 20190221 20181204161308 ACCESSION NUMBER: 0000921895-18-003192 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20181204 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GLOBALSCAPE INC CENTRAL INDEX KEY: 0001112920 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-PREPACKAGED SOFTWARE [7372] IRS NUMBER: 742785449 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4500 LOCKHILL SELMA STREET 2: STE 150 CITY: SAN ANTONIO STATE: TX ZIP: 78249 BUSINESS PHONE: 2103088267 MAIL ADDRESS: STREET 1: 4500 LOCKHILL SELMA STREET 2: STE 150 CITY: SAN ANTONIO STATE: TX ZIP: 78249 CORRESP 1 filename1.htm

O L S H A N

1325 AVENUE OF THE AMERICAS ● NEW YORK, NEW YORK 10019
TELEPHONE: 212.451.2300 ● FACSIMILE: 212.451.2222

EMAIL: AFINERMAN@OLSHANLAW.COM

DIRECT DIAL: 212.451.2289

December 4, 2018

VIA EMAIL AND EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance
100 F Street, N.E., Mail Stop 3030
Washington, D.C. 20549
Attention: Mitchell Austin

Staff Attorney

Re:

GlobalSCAPE, Inc.
Registration Statement on Form S-1 (No. 333-228449)

Ladies and Gentlemen:

On behalf of GlobalSCAPE, Inc. (the “Company”), we enclose the Company’s request for acceleration of the above-referenced Registration Statement to 10:00 a.m., Eastern time, on Thursday, December 6, 2018, or as soon as possible thereafter, and acknowledgement of the statements contained in the U.S. Securities and Exchange Commission’s letter to the Company.

Please advise the undersigned of the effectiveness of the Registration Statement.

	Very truly yours,

	/s/ Adam W. Finerman

	Adam W. Finerman

cc:

Matt Goulet
Karen Young



O L S H A N F R O M E W O L O S K Y L L P	WWW.OLSHANLAW.COM

GlobalSCAPE, Inc.
4500 Lockhill-Selma, Suite 150
San Antonio, TX 78249

December 4, 2018

U.S. Securities and Exchange Commission

Division of Corporation Finance
100 F Street, N.E., Mail Stop 3030
Washington, D.C. 20549
Attention: Mitchell Austin

Staff Attorney

Re:

GlobalSCAPE, Inc.
Registration Statement on Form S-1 (No. 333-228449)

Ladies and Gentlemen:

GlobalSCAPE, Inc. (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement be accelerated so that it will become effective at 10:00 a.m., Eastern time, on Thursday, December 6, 2018, or as soon as possible thereafter.

In connection with the Company’s request for acceleration of the effective date of the Registration Statement, the Company acknowledges:

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

the action of the SEC or its 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 SEC or any person under the federal securities laws of the United States.

	Very truly yours,

	GLOBALSCAPE, INC.


	By:	/s/ Matt Goulet
		Matt Goulet
		Chief Executive Officer