Elastic N.V. Notice and Access No-Action Relief for Dutch Law Conflict

Elastic N.V.

Response of the Office of Mergers and Acquisitions
Division of Corporation Finance

April 8, 2026

Via Email

Richard J. Parrino
Hogan Lovells US LLP
richard.parrino@hoganlovells.com

Re: Elastic N.V.
Incoming letter dated April 8, 2026

Dear Mr. Parrino:

We are responding to your letter dated April 8, 2026, addressed to Tiffany Posil and Laura McKenzie. To avoid having to recite or summarize the facts set forth in your letter, we attach a copy of your letter. Unless otherwise noted, capitalized terms in this response letter have the same meaning as in your letter.

Based on the facts and representations presented in your letter, the Division of Corporation Finance will not object if Elastic N.V. uses notice and access pursuant to Rule 14a-16 of the Exchange Act to furnish proxy materials as described in your incoming letter.

In particular, we note:

• Because Dutch law mandates that the record date for a general meeting of shareholders be set at the 28 th day before the date of the meeting, the Company is unable to comply with the requirement in Rule 14a-16(a) to send a Notice of Internet Availability of Proxy Materials (“Notice”) at least 40 calendar days before the shareholder meeting date;
• the Company undertakes to file its definitive proxy statement and annual report with the Commission, and to make such materials available on the Company’s website, at least 40 calendar days in advance of the general meeting, as described in your letter;
• the Company undertakes to issue a press release announcing the availability of its proxy statement and annual report, that the Company intends to use notice and access, the date on which the Company expects to distribute the Notice, and the manner in which shareholders can request paper copies of the proxy materials, as described in your letter; and
• the Company undertakes to distribute the Notice as quickly as practicable following its receipt of the shareholder list as of the record date and such distribution is expected to be completed within 5 business days after the record date. This position is based on the representations made to the Division in your letter. Any different facts or conditions may require the Division to reach a different conclusion. Further, this response does not express any legal conclusion on the questions presented or any views on any other questions that your request may raise.

Sincerely,

/s/ Tiffany Posil

Tiffany Posil
Chief, Office of Mergers and Acquisitions
Division of Corporation Finance

Last Reviewed or Updated: April 8, 2026

Resources

• Incoming Letter