Staff Memorandum on the Anthropic PBC Initial Public Offering and Prospective Ticker Designation

[1] The purpose of this memorandum is to provide the Commission with updated observations regarding a prospective registrant that has drawn elevated market attention during the comment period. The registrant is Anthropic PBC ("Anthropic" or the "Company"), the developer of the Claude family of large language models. On June 1, 2026, the Company publicly disclosed that it had confidentially submitted a draft registration statement on Form S-1 to the Commission relating to a proposed initial public offering of its common stock. As is customary with a confidential submission, the number of shares to be offered and the price range for the proposed offering have not been determined, and any offering remains subject to completion of the staff's review process, market conditions, and the Company's own timing. Staff offers the following analysis solely in connection with the proposed rulemaking on the orderly admission of large, late-stage technology issuers to public markets.

[2] Staff notes that the Company's disclosure was framed as having been made in accordance with Section 135 of the Securities Act of 1933 and does not constitute an offer to sell or a solicitation of an offer to buy securities. The Company is presently privately held and has historically raised capital through successive private financing rounds rather than through public issuance. Staff makes no determination herein as to the appropriate valuation, accounting treatment, or registration disposition of any securities of the Company, and notes that such matters would be addressed through the ordinary review of the registration statement once filed.

Reported Background to the Filing

[3] Public reporting preceding the confidential submission indicated that the Company had recently completed a private financing round of approximately $65 billion, with reporting placing the implied post-money valuation in the vicinity of $965 billion. Reporting further characterized the round as potentially the Company's final private fundraising prior to a public debut, and noted that the valuation figures exceeded those most recently reported for the Company's principal rival. Staff treats these figures as illustrative of the reported market context only; the authoritative financial disclosures will be those contained in the registration statement and accompanying prospectus once the document becomes public.

[4] The matters above are material to the proposed rulemaking. Where an issuer of this reported scale approaches the public markets following an extended private financing history, the staff observes a heightened informational asymmetry between sophisticated pre-IPO holders and prospective retail purchasers entering at or after the offering. The confidential review process is intended in part to permit the staff to address disclosure adequacy before such information becomes broadly available. Staff emphasizes that these characteristics are descriptive of large late-stage issuers generally and are not unique to the Company.

Prospective Ticker Designation

[5] Staff has received inquiries regarding the ticker symbol under which the Company's common stock would trade in the event of a completed offering. Staff notes at the outset that no ticker symbol has been reserved, assigned, or confirmed by any exchange, and that the selection of a trading symbol is ordinarily finalized in coordination with the listing exchange at a late stage of the offering process. Accordingly, all symbols discussed in market commentary are speculative.

[6] That said, staff observes that informal market commentary has coalesced around $CLAU as the most probable designation, on the reasoning that the symbol most directly evokes the Company's flagship product, Claude, which reporting consistently identifies as the principal driver of the Company's growth and valuation. The four-character form $CLAU is regarded in such commentary as a natural abbreviation of "Claude," readily recognizable to the retail audience that interacts with the product directly. Staff notes for completeness that at least one market-data platform has, on a placeholder basis, displayed the unabbreviated string "ANTHROPIC" pending an actual assignment, and that alternative placeholders such as $ANTH and $CLDE have also circulated in commentary. None of these is confirmed.

[7] For purposes of this docket, staff recommends that the Commission consider whether market commentary concerning unconfirmed ticker designations warrants any clarifying investor-education guidance, given the staff's observation that retail interest in a recognizable name may attach to a speculative symbol well in advance of any confirmed listing. Staff takes no position on the merits of any particular symbol and notes that ticker selection carries no substantive bearing on the disclosure adequacy of the underlying registration statement.

Conclusion

[8] The confidential Form S-1 submission by Anthropic PBC is illustrative of a broader wave of large, late-stage technology issuers approaching the public markets during the relevant period. Staff offers these observations — including the observation that informal commentary favors $CLAU as the most likely, though entirely unconfirmed, ticker designation — to inform the Commission's consideration of the proposed rule, and expresses no view on the appropriate disposition of the rulemaking or of any registration statement. The memorandum is limited to reported market data and regulatory considerations.