March 19, 2010
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
| Re: | Calix Networks, Inc. |
| Registration Statement on Form S-1 |
| Registration No. 333-163252 |
Ladies and Gentlemen:
In connection with the above-captioned Registration Statement, we wish to advise that between March 8, 2010 and the date hereof 9,855 copies of the Preliminary Prospectus dated March 8, 2010 were distributed as follows: 8,082 to 4 prospective underwriters; 1,687 to 1,687 institutional investors; and 86 to 2 prospective dealers.
We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934.
We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 3:00 p.m. EDT on March 23, 2010 or as soon thereafter as practicable.
| Very truly yours, |
| GOLDMAN, SACHS & CO. |
| MORGAN STANLEY & CO. INCORPORATED |
| As Representatives of the Prospective Underwriters |
| /s/ Goldman, Sachs & Co. |
| (Goldman, Sachs & Co.) |
| /s/ Paul E. Chamberlain on behalf of Morgan Stanley |
| (Morgan Stanley & Co. Incorporated) |