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September 27, 2021
Via EDGAR
Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 |
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Attn: | Dale Welcome |
John Cash
Thomas Jones
Sherry Haywood
Division of Corporation Finance
Office of Manufacturing
Re: | Bird Global, Inc. |
Amendment No. 4 to Registration Statement on Form S-4
Filed September 3, 2021
File No. 333-256187
Ladies and Gentlemen:
On behalf of our client, Bird Global, Inc. (the Company), we submit this letter setting forth the responses of the Company to the comments provided by the staff (the Staff) of the Securities and Exchange Commission (the Commission) in its comment letter dated September 24, 2021 (the Comment Letter) with respect to Amendment No. 4 to the Registration Statement on Form S-4 filed with the Commission by the Company on September 3, 2021. Concurrently with the filing of this letter, the Company has filed Amendment No. 5 to the Registration Statement on Form S-4 (the Registration Statement) through EDGAR.
For your convenience, we have set forth each comment of the Staff from the Comment Letter in bold and italics below and provided our response below each comment. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Registration Statement.
General
1. | We refer to Exhibit 23.1 appearing in Amendment No. 3 to Form S-4. Since Bird Rides and Bird Globals latest consent from Ernst & Young LLP, dated August 18, 2021, specifically references Amendment No. 3 to the registration statement, please ensure that you amend your filing to include a currently dated consent prior to requesting effectiveness. |
Response: The Company acknowledges the Staffs comment and has revised Exhibit 23.1 to the Registration Statement accordingly.
September 27, 2021
Page 2
* * * *
We hope that the foregoing has been responsive to the Staffs comments and look forward to resolving any outstanding issues as quickly as possible. Please direct any questions or comments regarding the foregoing to me at (202) 637-2139 or my colleague, Christopher J. Clark, at (202) 637-2374.
Very truly yours, |
/s/ Rachel W. Sheridan |
Rachel W. Sheridan of LATHAM & WATKINS LLP |
cc: | Travis VanderZanden, Bird Global, Inc. |
Wendy Mantell, Bird Global, Inc.
Jim Mutrie, Switchback II Corporation
Justin G. Hamill, Latham & Watkins LLP
Christopher J. Clark, Latham & Watkins LLP
Douglas E. McWilliams, Vinson & Elkins L.L.P.
E. Ramey Layne, Vinson & Elkins L.L.P.