ACV AUCTIONS INC.
640 Ellicott Street, #321
Buffalo, New York 14203
March 19, 2021
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
ACV Auctions Inc.
Registration Statement on Form S-1
File No. 333-253617
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, ACV Auctions Inc. (the Company) hereby requests that the Securities and Exchange Commission (the Commission) accelerate the effective date of the above-referenced Registration Statement on Form S-1 (as amended, the Registration Statement) and declare the Registration Statement effective as of 4:00 p.m. Eastern time, on March 23, 2021, or as soon as thereafter practicable, or at such later time as the Company may orally request via telephone call to the staff of the Commission. The Company hereby authorizes each of Nicole Brookshire and Alan Hambelton of Cooley LLP, counsel to the Company, to make such request on its behalf.
Once the Registration Statement has been declared effective, please orally confirm that event with Nicole Brookshire of Cooley LLP, counsel to the Company, at (617) 937-2357, or in her absence, Alan Hambelton at (206) 452-8756.
[SIGNATURE PAGE FOLLOWS]
|Very truly yours,|
|ACV AUCTIONS INC.|
|Title:||Chief Executive Officer|
William Zerella, ACV Auctions Inc.
Nicole Brookshire, Cooley LLP
Alan Hambelton, Cooley LLP
Shauna Bracher, Cooley LLP
Trey Reilly, Cooley LLP
Richard Truesdell, Jr., Davis Polk & Wardwell LLP
Pedro J. Bermeo, Davis Polk & Wardwell LLP