Clearwater Analytics Holdings, Inc.
777 W. Main Street
Suite 900
Boise, ID 83702
March 10, 2025
VIA EDGAR
Securities and Exchange Commission
Division of Corporate Finance
Office of Technology
100 F Street, NE
Washington, D.C. 20549
| Attention: | Mitchell Austin Jan Woo |
| Re: | Clearwater Analytics Holdings, Inc. Registration Statement on Form S-4 File No. 333-284816 |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Clearwater Analytics Holdings, Inc. (the “Company”) hereby requests acceleration of the effective date of the above referenced Registration Statement to 4:00 p.m., Eastern Time, on March 12, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Kirkland & Ellis LLP, request by telephone that such Registration Statement be declared effective.
Please contact Ross M. Leff of Kirkland & Ellis LLP at (212) 446-4947 or Christie W.S. Mok of Kirkland & Ellis LLP at (212) 390-4546 as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
| Sincerely,
Clearwater Analytics Holdings, Inc. |
| /s/ Alphonse Valbrune |
| Alphonse Valbrune |
| Chief Legal Officer |
| cc: | Sandeep Sahai Clearwater Analytics Holdings, Inc. | |
| Constantine N. Skarvelis Marshall P. Shaffer Ross M. Leff Christie W.S. Mok Kirkland & Ellis LLP | ||