CALIX NETWORKS, INC.
1035 N. MCDOWELL BOULEVARD
PETALUMA, CA 94954
March 19, 2010
VIA FACSIMILE AND EDGAR TRANSMISSION
Securities and Exchange Commission
Mail Stop 3720
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Larry Spirgel, Assistant Director | |
| Kathleen Krebs, Special Counsel | ||
| Jay Knight, Staff Attorney | ||
| Kyle Moffatt, Account Branch Chief | ||
| Sharon Virga, Staff Accountant |
| Re: | Calix Networks, Inc. |
Registration Statement on Form S-1 (Registration No. 333-163252)
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-1 (File No. 333-163252) (the “Registration Statement”) of Calix Networks, Inc. (the “Company”). We respectfully request that the Registration Statement become effective as of 3:00 p.m., Washington, D.C. time, on March 23, 2010, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Michael Torosian at (650) 463-3015.
The Company acknowledges the following:
| • | Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | The action of the Commission or the staff, acting pursuant to delegated authority in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Thank you for your assistance in this matter.
| Very truly yours, | ||
| CALIX NETWORKS, INC. | ||
| By: | /s/ Kelyn Brannon-Ahn | |
| Kelyn Brannon-Ahn | ||