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1700 K Street, NW, Fifth Floor Washington, D.C. 20006-3817
PHONE 202.973.8800 FAX 202.973.8899
www.wsgr.com |
August 21, 2018
VIA EDGAR AND COURIER
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
| Attn: | Michael Foland, Attorney-Advisor |
| Folake Ayoola, Special Counsel |
| Re: | Acxiom Corporation |
| Preliminary Proxy Statement on Schedule 14A |
| Filed August 3, 2018 |
| File No. 000-13163 |
Ladies and Gentlemen:
On behalf of our client, Acxiom Corporation (the “Company”), we hereby submit this letter in response to comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated August 17, 2018 (the “Staff Letter”) relating to the Company’s Preliminary Proxy Statement on Schedule 14A (the “Proxy Statement”) filed with the Commission on August 3, 2018 (File No. 000-13163). The Company is concurrently filing this letter via EDGAR.
In this letter, we have recited the comments from the Staff Letter in bold and italicized type and have followed each comment with the Company’s response. Unless otherwise defined in this letter, capitalized terms shall have the meaning ascribed to such terms in the Proxy Statement. References to “we,” “our” or “us” mean the Company or its advisors, as the context may require.
AUSTIN BEIJING BOSTON BRUSSELS HONG KONG LOS ANGELES NEW YORK PALO ALTO
SAN DIEGO SAN FRANCISCO SEATTLE SHANGHAI WASHINGTON, DC WILMINGTON, DE
U.S. Securities and Exchange Commission
August 21, 2018
Page 2
PREM14A
General
| 1. | We note that you provided the summary selected financial data for the AMS Business. Please also provide audited or unaudited financial statements of the AMS Business for the same periods. For guidance, please refer to Section H.6. of our July 2001 Interim Supplement to Publicly Available Telephone Interpretations. |
RESPONSE TO COMMENT 1:
The Company acknowledges the Staff’s comment and advises the Staff that it will amend the Proxy Statement to provide the referenced financial statements for the fiscal years ended March 31, 2017 and 2018 and for the three months ended June 30, 2018 of the AMS Business (the “AMS Financial Statements”). The Company is supplementally providing the AMS Financial Statements that it expects to file with the Proxy Statement to the Staff as Appendix A herewith.
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U.S. Securities and Exchange Commission
August 21, 2018
Page 3
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Please direct your questions or comments regarding this letter to the undersigned at (202) 973-8823 or Mark Bass at (202) 973-8826. Thank you for your assistance.
| Sincerely, |
| WILSON SONSINI GOODRICH & ROSATI, PROFESSIONAL CORPORATION |
| /s/ Michael Labriola |
| Michael C. Labriola |
| cc: | Jerry Jones, Acxiom Corporation |
Warren Jenson, Acxiom Corporation
Mark Bass, Wilson Sonsini Goodrich & Rosati, P.C.