CORRESP 1 filename1.htm

 

  New York
Northern California
Washington DC
São Paulo
London

Paris
Madrid
Tokyo
Beijing
Hong Kong

 

Sarah K. Solum

 

 
Davis Polk & Wardwell LLP
1600 El Camino Real
Menlo Park, CA 94025
650 752 2011 tel
650 752 3611 fax
[email protected]
 
       

 

July 21, 2017

 

VIA EDGAR


 

U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

 

Attention: William H. Thompson
  Accounting Branch Chief
  Office of Consumer Products
   
  Yolanda Guobadia
  Staff Accountant

 

Re:Letter dated July 18, 2017 to TriNet Group, Inc. (“TriNet”) regarding TriNet’s Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 28, 2017 (File No. 1-36373)

 

Dear Ms. Guobadia and Mr. Thompson:

 

On behalf of TriNet Group, Inc., thank you for your letter dated July 18, 2017 regarding TriNet’s Form 10-K for the most recently completed fiscal year. TriNet is currently in the midst of preparing its Form 10-Q for the six months ended June 30, 2017, which it anticipates filing on or about August 2, 2017, and will be holding its annual sales conference shortly after the Form 10-Q filing. In addition, as previously disclosed, TriNet has recently undergone a change in its principal financial and principal accounting officers. Accordingly, TriNet very much appreciates the Staff’s willingness to allow TriNet time to carefully consider and respond to each comment in the letter. This letter is to confirm, on behalf of TriNet, our conversation today that TriNet will respond to your letter no later than August 18, 2017. Please feel free to contact me at (650) 752-2011 with any questions.

 

 

  2 July 21, 2017

 

 

        Very truly yours,  
             
             
      /s/ Sarah K. Solum  
        Sarah K. Solum
         
             

 

  

   
cc: Burton M. Goldfield, Chief Executive Officer
  Richard Beckert, Chief Financial Officer
  Michael Murphy, Chief Accounting Officer
  Brady Mickelsen, Chief Legal Officer
  (TriNet Group, Inc.)