Barclays Capital Inc.
745 Seventh Avenue
New York, New York 10019
Stifel, Nicolaus & Company, Incorporated
787 Seventh Avenue, 11th Floor
New York, New York 10019
November 18, 2019
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Geoffrey Kruczek, Esq., Special Counsel |
Thomas Jones, Esq., Legal Staff Attorney
Kevin Kuhar, Accounting Branch Chief
Gary Newberry, Senior Staff Accountant
| Re: | SiTime Corporation |
Registration Statement on Form S-1
Registration File No. 333-234305
Dear Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of SiTime Corporation (the “Company”) for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 4:00 PM, Eastern Time, on November 20, 2019, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Pillsbury Winthrop Shaw Pittman LLP, request by telephone that such Registration Statement be declared effective.
Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that we have effected the following distribution of the Company’s preliminary prospectus dated November 7, 2019:
| i. | Dates of distribution: November 7, 2019 through the date hereof |
| ii. | Number of prospective underwriters to which the preliminary prospectus was furnished: 5 |
| iii. | Number of preliminary prospectuses furnished to investors: approximately 2086 |
| Securities and Exchange Commission 2 | November 18, 2019 |
| iv. | Number of preliminary prospectuses distributed to others, including the Company, the Company’s counsel, independent accountants, and underwriters’ counsel: approximately 51 |
We, the undersigned, as representatives of the several underwriters, have complied and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
| Very truly yours, | ||
| Barclays Capital Inc. Stifel, Nicolaus & Company, Incorporated | ||
| Acting severally on behalf of themselves and the several Underwriters | ||
| By: | Barclays Capital Inc. | |
| By: | /s/ Geoffrey Feldkamp | |
| Name: Geoffrey Feldkamp | ||
| Title: Managing Director | ||
| By: | Stifel, Nicolaus & Company, Incorporated | |
| By: | /s/ Seth Rubin | |
| Name: Seth Rubin | ||
| Title: Managing Director | ||
[Signature Page to Underwriters’ Acceleration Request]