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CORRESP Filing

SMITHFIELD FOODS INC
Date: Sept. 3, 2025 · CIK: 0000091388 · Accession: 0001213900-25-083716

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File numbers found in text: 333-290000

Date
September 3, 2025
Author
Executive Director
Form
CORRESP
Company
SMITHFIELD FOODS INC

Letter

Re: Smithfield Foods, Inc. Registration Statement Filed on Form S-1 File No. 333-290000

September 3, 2025

BY EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance 100 F Street, N.E.

Washington, D.C. 20549

Attention: Erin Donahue

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended (the "Act"), we, as representatives of the several underwriters, hereby join in the request of Smithfield Foods, Inc. (the "Company") for acceleration of the effective date of the above-referenced Registration Statement so that it becomes effective at 4:00 p.m., Eastern Time, on September 4, 2025 or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Paul Hastings LLP, request by telephone that such Registration Statement be declared effective.

Pursuant to Rule 460 under the Act, please be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to the underwriters, dealers, institutions and others, prior to the requested effective time of the Registration Statement.

We, the undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

Very truly yours,
Morgan Stanley & Co. LLC

Show Raw Text
CORRESP
 1
 filename1.htm

 September 3, 2025

 BY EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance
100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Erin Donahue

 Re: Smithfield Foods, Inc.
Registration Statement Filed on Form S-1
File No. 333-290000

 Ladies and Gentlemen:

 In accordance with Rule 461
under the Securities Act of 1933, as amended (the "Act"), we, as representatives of the several underwriters, hereby join
in the request of Smithfield Foods, Inc. (the "Company") for acceleration of the effective date of the above-referenced Registration
Statement so that it becomes effective at 4:00 p.m., Eastern Time, on September 4, 2025 or as soon thereafter as practicable, or at such
other time as the Company or its outside counsel, Paul Hastings LLP, request by telephone that such Registration Statement be declared
effective.

 Pursuant to Rule 460 under
the Act, please be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to the underwriters,
dealers, institutions and others, prior to the requested effective time of the Registration Statement.

 We, the undersigned, as representatives
of the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have
complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 [Signature Page Follows]

 Very truly yours,

 Morgan Stanley & Co. LLC

 BofA Securities, Inc.

 Barclays Capital Inc.

 As Representatives of the several Underwriters

 MORGAN STANLEY & Co. LLC

 /s/ Josh Kamboj

 Name:
 Josh Kamboj

 Title:
 Executive Director

 BOFA SECURITIES, INC.

 /s/ Ross Michler

 Name:
 Ross Michler

 Title:
 Managing Director

 BARCLAYS CAPITAL INC.

 /s/ Michaela Diverio

 Name:
 Michaela Diverio

 Title:
 Managing Director

 [Signature Page to Underwriters' Acceleration
Request]