April 5, 2012

U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Mail Stop 3561
Washington D.C.  20549
Re:       BATS Global Markets, Inc.
Request to Withdraw Registration Statement on Form S-1
File No. 333-174166

Ladies and Gentlemen:

Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended, BATS Global Markets, Inc., a Delaware corporation (the “Company”), hereby respectfully requests that the Securities and Exchange Commission (the “Commission”) consent to the immediate withdrawal of the Company’s Registration Statement on Form S-1 (File No. 333-174166) together with all exhibits and amendments thereto (the “Registration Statement”).  The Company is requesting such withdrawal because of its decision, taken together with the underwriters of the offering, to terminate the offering of the shares of Class A common stock covered by the Registration Statement. No securities were sold or will be sold under the Registration Statement.  The Registration Statement was originally filed with the Commission on May 13, 2011 and was declared effective on March 22, 2012.

Accordingly, we hereby request that an order granting the withdrawal of the Registration Statement be issued by the Commission as soon as possible.  Should you have any questions or require any further information please contact Deanna Kirkpatrick at (212) 450-4135 or Jeff Ramsay at (212) 450-4243.  Thank you for your assistance with this application for withdrawal.
/s/ Joe Ratterman  
    Name: Joe Ratterman  
    Title:   Chairman, President and Chief Executive Officer

Deanna L. Kirkpatrick
Jeffrey S. Ramsay
    Davis Polk & Wardwell LLP
TEL. 913.815.7000  |  FAX. 913.815.7119  |  8050 MARSHALL DRIVE, SUITE 120  |  LENEXA, KS 66214-1585  |  BATSTRADING.COM