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October 2, 2018
Via EDGAR and Overnight Delivery
U.S. Securities and Exchange Commission
Office of Global Security Risk
100 F Street, N.E.
Washington, D.C. 20549
Attn: Cecilia Blye, Chief
Re: Cornerstone OnDemand, Inc.
10-K for Fiscal Year Ended December 31, 2017
Filed February 27, 2018
File No. 001-35098
Dear Ms. Blye:
On behalf of Cornerstone OnDemand, Inc. (“Cornerstone” or the “Company”), we are responding to a comment letter, dated September 18, 2018, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2017 filed with the Commission on February 27, 2018 (the “2017 10-K”) and certain statements contained in a 2018 press release on the Company’s website...
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*The version of the GL in force as of the time of the correspondence can be found at https://www.govinfo.gov/content/pkg/CFR-2020-title31-vol3/xml/CFR-2020-title31-vol3-part542.xml#seqnum542.516. Note that the below was drafted prior to the November, 2021 revisions to 541.516.
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1) The 2018 press release to which Cornerstone OnDemand (Cornerstone) refers can be found here. The press release explains that a “nonprofit organization” founded by Cornerstone had, “in partnership with Mercy Corps and the International Rescue Committee (IRC), [] announced the results of the first phase of its [USAID Office of Foreign Disaster Assistance]-funded program, Investing in Syrian Humanitarian Action (ISHA), which [had] provided online learning to more than 13,000 aid workers, allowing them to more effectively respond to humanitarian needs across Syria.”
The letter to the SEC explains that the “[Cornerstone OnDemand]...