0001193125-14-269015.txt : 20140814 0001193125-14-269015.hdr.sgml : 20140814 20140715143910 ACCESSION NUMBER: 0001193125-14-269015 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140715 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TRUPANION INC. CENTRAL INDEX KEY: 0001371285 STANDARD INDUSTRIAL CLASSIFICATION: HOSPITAL & MEDICAL SERVICE PLANS [6324] IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 907 NW BALLARD WAY CITY: SEATTLE STATE: WA ZIP: 98107 BUSINESS PHONE: 888-738-7478 MAIL ADDRESS: STREET 1: 907 NW BALLARD WAY CITY: SEATTLE STATE: WA ZIP: 98107 FORMER COMPANY: FORMER CONFORMED NAME: VETINSURANCE INTERNATIONAL INC DATE OF NAME CHANGE: 20060802 CORRESP 1 filename1.htm CORRESP

July 15, 2014

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington D.C. 20549-3561

Attention: Scott Foley

 

Re: Acceleration Request of Trupanion, Inc.
  Registration Statement on Form S-1 (File No. 333-196814)

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as the representatives of the several underwriters, hereby join in the request of Trupanion, Inc. for acceleration of the effective time of the above-referenced Registration Statement, as amended, so that it may be declared effective Thursday, July 17, 2014, at 4:15 p.m. Eastern Time, or as soon thereafter as practicable.

In connection with this acceleration request and pursuant to Rule 460 under the Securities Act, we hereby advise you that the Preliminary Prospectus, dated July 7, 2014, was distributed by the several underwriters approximately as follows from July 7, 2014 through the date hereof:

 

To Whom Distributed

    Number of Copies  

Retail Investors

      3,007   

Institutional Investors

      1,172   
  

 

 

  

Total

      4,179   

The undersigned, as the representatives of the several underwriters, hereby represent that we have complied and will comply with the requirements of Rule 15c2-8 of the Securities Exchange Act of 1934, as amended, in connection with the above proposed offering.

Sincerely yours,

 

RBC Capital Markets, LLC

/s/ Jennifer Caruso

Name:

   Jennifer Caruso

Title:

   Director

Barclays Capital Inc.

/s/ Jason van Itallie

Name:

   Jason van Itallie

Title:

   Managing Director

Stifel, Nicolaus & Company, Incorporated

/s/ Daniel J. Covatta

Name:

   Daniel J. Covatta

Title:

   Managing Director