SEC Division of Corporation Finance no-action letter: Elastic N.V.

April 8, 2026

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 28th 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 10, 2026

Resources

• Incoming Letter

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Advocaten
Notarissen
Belastingadviseurs
DE BRAUW
BLACKSTONE
WESTBROEK
Elastic N.V.
Attn: Marielle Reints
Mark Kam
Keizersgracht 281
1016 ED Amsterdam
The Netherlands
Date April 8, 2026
Our ref. M46958737/1/74707531/T.
Re: Elastic N.V.
Casper Nagtegaal
E casper.nagtegaal@debrauw.com
T +31 20 577 1075 (direct)
T +31 20 577 1098 (secretary)
Rule 14a-16(a) under the Exchange Act
Dear Ms Reints and Mr Kam,
De Brauw Blackstone Westbroek N.V. is acting as Dutch legal counsel to Elastic N.V., a public limited liability company (naamloze vennootschap) incorporated under the laws of the Netherlands. In such capacity, I have reviewed the letter related to Rule 14a-16(a) under the Securities Exchange Act of 1934, as amended, prepared by Hogan Lovells US LLP ("Hogan Lovells") and dated as of April 8, 2026 (the "Letter"), and confirm that in my opinion the descriptions of Dutch law, regulations and practices contained therein are fair and accurate as per the date hereof. The foregoing confirmation is limited to matters involving the laws of the Netherlands and is not intended to be read as extending by implication to any other matters not referred to herein. In particular, I have not considered any U.S. federal or state laws, rules, regulations, procedures or practices and I have not provided advice as to, or analysed, whether the request in the Letter is appropriate, justified or complete with respect to U.S. federal or state laws, rules, regulations, procedures and practices. The foregoing confirmation may be relied upon by the United States Securities and Exchange Commission for the purpose set out in the Letter and not by any other person or party or for any other purpose. De Brauw Blackstone Westbroek N.V., Amsterdam, is registered with the Trade Register In the Netherlands under no. 27171912. All services and other work are earned out under an agreement of instruction ("overeenkomst van opdracht") with De Brauw Blackstone Westbroek N.V. The agreement Is subject to the General Conditions, which have been filed with the register of the District Court in Amsterdam and contain a limitation of liability. Client account notaries ING Bank IBAN NL83INGB0693213876 BIG INGBNL2A Burgerweeshuispad 201 P.O. Box 75084 1070 AB Amsterdam The Netherlands T +31 20 577 1771 F +31 20 577 1775 1 / 2

DE BRAUW
BLACKSTONE
WESTBROEK
I hereby consent to the inclusion of a copy of this letter with the Letter submitted by Hogan Lovells on your behalf to the United States Securities and Exchange Commission. /J ; Kind regards, .,. er/ Our ref. M46958737/1/74707531 2/2