Credit Suisse Securities (USA) LLC
Eleven Madison Avenue
New York, New York 10010-3629
Deutsche Bank Securities Inc.
60 Wall Street, 4th Floor
New York, New York 10005
April 29, 2011
Via Edgar and Facsimile
Securities and Exchange Commission
Division of Corporate Finance
100 F. Street, N.E.
Washington D.C. 20549
Attention: Larry Spirgel
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Re: |
Boingo Wireless, Inc. (the “Company”) |
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Registration Statement on Form S-1 |
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File No. — 333-171719 |
Dear Ladies and Gentleman:
Pursuant to Rule 460 under the Securities Act of 1933, as amended, the undersigned, as representatives of the several underwriters of the proposed initial public offering of shares of common stock of the Company, hereby advise you that the Preliminary Prospectus, dated April 18, 2011 and included in Amendment No. 4 to the above-referenced Registration Statement, filed with the Securities and Exchange Commission on April 18, together with the issuer free writing prospectus dated April 25, 2011, was distributed during the period April 18, 2011 through the date hereof as follows:
· 1,483 to dealers
· 1,992 to institutions
· 439 to others
Total: 3,914 Preliminary Prospectuses
The undersigned advise that they have complied and will continue to comply, and each participating underwriter and dealer has advised the undersigned that it has complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934.
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby join in the request of the Company that the effective date of the above-referenced Registration Statement be accelerated so that the Registration Statement may become effective on May 3, 2011 at 4:00 p.m. Eastern Daylight Time, or as soon as practicable thereafter.
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Very truly yours, | ||
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CREDIT SUISSE SECURITIES (USA) LLC | ||
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DEUTSCHE BANK SECURITIES INC. | ||
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Acting on behalf of themselves and as the Representatives of the several Underwriters. | ||
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By: |
CREDIT SUISSE SECURITIES (USA) LLC | |
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By: |
/s/ C.Cullom Davis | |
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Name: |
C. Cullom Davis |
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Title: |
Managing Director |
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By: |
DEUTSCHE BANK SECURITIES INC. | |
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By: |
/s/ Joseph P. Coleman | |
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Name: |
Joseph P. Coleman |
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Title: |
Managing Director |
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By: |
/s/ Brad Miller | |
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Name: |
Brad Miller |
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Title: |
Managing Director |