United States securities and exchange commission logo
March 26, 2024
Dr. Babak A. Taheri
Chief Executive Officer
Silvaco Group, Inc.
4701 Patrick Henry Drive, Building #23
Santa Clara, CA 95054
Re: Silvaco Group, Inc.
Amendment No. 6 to
Draft Registration Statement on Form S-1
Submitted March 18,
2024
CIK No. 0001943289
Dear Dr. Babak A. Taheri:
We have reviewed your amended draft registration statement and have
the following
comment.
Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to this
letter and your amended
draft registration statement or filed registration statement, we may
have additional comments.
Amendment No. 6 to Draft Registration Statement on Form S-1
Use of Proceeds, page 53
1. We note that the
company intends to use a portion of the offering proceeds to repay the
2022 Credit Line and
the East West Bank Loan. Please expand your disclosure to include
the interest rates and
maturity of such indebtedness. Refer to Item 504 of Regulation S-K.
Dr. Babak A. Taheri
FirstName LastNameDr. Babak A. Taheri
Silvaco Group, Inc.
Comapany
March NameSilvaco Group, Inc.
26, 2024
March2 26, 2024 Page 2
Page
FirstName LastName
Please contact Joseph Kempf at 202-551-3352 or Robert Littlepage at
202-551-3361 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alexandra Barone at 202-551-8816 or Matthew Crispino at 202-551-3456
with any other
questions.
Sincerely,
Division of
Corporation Finance
Office of Technology
cc: Drew Valentine