|
|
New York Menlo Park Washington DC São Paulo London |
Paris Madrid Tokyo Beijing Hong Kong | |
|
|
|
| |
|
|
|
| |
|
Deanna L. Kirkpatrick |
|
| |
|
|
|
| |
|
Davis Polk & Wardwell LLP 450 Lexington Avenue New York, NY 10017 |
212 450 4135 tel 212 701-5135 fax deanna.kirkpatrick@davispolk.com |
| |
|
March 30, 2016 | ||
|
| ||
|
Re: |
Bats Global Markets, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed March 7, 2016 File No. 333-208565 |
|
|
|
|
|
|
|
|
CONFIDENTIAL |
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attention: Tom Kluck
Nicole Collings
Jeffrey Lewis
Robert Telewicz
Ladies and Gentlemen:
On behalf of our client, Bats Global Markets, Inc., enclosed please find Exhibit A, containing pages of the draft Amendment No. 3 to the Registration Statement on Form S-1 (the “New Disclosure”) marked against Amendment No. 2 to the Registration Statement on Form S-1 that was submitted on March 7, 2016 via EDGAR to the Securities and Exchange Commission (the “Commission”) in response to your letter dated February 26, 2016. In addition to including price range information, the New Disclosure also reflects the disclosure contained in the Company’s response letter to be dated April 4, 2016 in response to the Staff of the Commission’s letter dated March 26, 2016.