SEC Comment Letter for TEAM INC (TISI) (CIK 0000318833) (TISI) — Dec 28, 2015

TEAM INC (TISI) (CIK 0000318833)
Date: Dec. 28, 2015 · CIK: 0000318833 · Accession: 0000000000-15-059578

View on Edgar

AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

Dec. 28, 2015

Author

/s/ Larry Spirgel

Form

UPLOAD

Company

TEAM INC (TISI) (CIK 0000318833)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3720 December 28 , 2015 Andre C. Bouchard , Esq. Chief Legal Officer Team , Inc. 13131 Dairy Ashford, Suite 600 Sugar Land, Texas 77478

RE: Team , Inc. Registration Statement on Form S -4 Filed on December 24 , 2015 File No. 333 -208756

Dear Mr. Bouchard :

This is to advise you that we have not reviewed and will not review your registration statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration statement please provide a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

Andre C, Bouchard , Esq. Team , Inc. December 28 , 2015 Page 2

 the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1 933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .

You may contact Paul Fischer at 202-551-3415 with any questions.

Sincerely,
/s/ Larry Spirgel

Show Raw Text

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3720

December 28 , 2015

Andre C. Bouchard , Esq.
Chief Legal  Officer
Team , Inc.
13131 Dairy Ashford, Suite 600
Sugar Land, Texas 77478

RE:  Team , Inc.
Registration Statement on Form S -4
  Filed on December 24 , 2015
File No. 333 -208756

Dear Mr. Bouchard :

This is to advise you that we have not reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities Act
of 193 3 and all applicable Securities  Act rules require.   Since the company and its
management are  in possession of all facts relating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration
statement please provide  a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

Andre C, Bouchard , Esq.
Team , Inc.
December 28 , 2015
Page 2

  the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will
consider a written request for acceleration of the effective date of the registration statement
as confirmation of the fact that those requesting acceleration are aware of their respective
responsibilities under the Securities Act of 1 933 and the Securities Exchange Act of 1934 as
they relate to the proposed public offering of the registered securities .

You may contact Paul Fischer  at 202-551-3415  with any questions.

Sincerely,

 /s/ Larry Spirgel

 Larry Spirgel
Assistant Director
AD11 —Telecommunications

Cc:  David F. Taylor , Esq.

SecProbe.io