Correspondence 0001193125-23-017366 from S&P Global Inc. (SPGI) (CIK 0000064040) (SPGI)
S&P Global Inc. (SPGI) (CIK 0000064040)
Date: Jan. 27, 2023 · CIK: 0000064040 · Accession: 0001193125-23-017366
AI Filing Summary & Sentiment
File numbers found in text: 333-269237
Letter
S&P Global Inc.
55 Water Street
New York, New York
January 27, 2023
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C.
Re: S&P Global Inc.
Registration Statement on Form S-4
File No. 333-269237
Request for Acceleration
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, S&P Global Inc. (the “Issuer”) and the additional registrant listed in the Registration Statement (together, with the Issuer, the “Registrants”) on Form S-4 (File No. 333-269237), as amended (the “Registration Statement”) hereby request acceleration of the effective date of their Registration Statement, so that it may become effective at 2 p.m., Washington, D.C. time, on January 31, 2023, or as soon thereafter as practicable.
The Registrants hereby acknowledge that:
(i) should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
(ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
(iii) the Registrants may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
S&P Global Inc.
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CORRESP 1 filename1.htm CORRESP S&P Global Inc. 55 Water Street New York, New York 10041 January 27, 2023 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: S&P Global Inc. Registration Statement on Form S-4 File No. 333-269237 Request for Acceleration Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, S&P Global Inc. (the “Issuer”) and the additional registrant listed in the Registration Statement (together, with the Issuer, the “Registrants”) on Form S-4 (File No. 333-269237), as amended (the “Registration Statement”) hereby request acceleration of the effective date of their Registration Statement, so that it may become effective at 2 p.m., Washington, D.C. time, on January 31, 2023, or as soon thereafter as practicable. The Registrants hereby acknowledge that: (i) should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; (ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and (iii) the Registrants may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Very truly yours, S&P Global Inc. By: /s/ Christopher F. Craig Name: Christopher F. Craig Title: Senior Vice President, Controller and Chief Accounting Officer