SEC Comment Letter for AECOM (ACM) — Jul 9, 2015
AECOM
Date: July 9, 2015 · CIK: 0000868857 · Accession: 0000000000-15-035995
AI Filing Summary & Sentiment
File numbers found in text: 333-205512
Letter
July 9, 2015 Via E -Mail Charles Szurgot Securities and Corporate Counsel AECOM 1999 Avenue of the Stars, Suite 2600 Los Angeles, CA 90067
Re: AECOM Registration Statement on Form S-4 Filed July 6 , 201 5 File No. 333-205512
Dear Mr. Szurgot :
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 1933 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 registrati on 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
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 46 1 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 un der
Charles Szurgot AECOM July 9, 2015 Page 2
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities.
You may contact David Korvin at 202 -551-3236 or me at 202 -551-3397 with any questions.
Sincerely,
/s/ Jay Ingram
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July 9, 2015 Via E -Mail Charles Szurgot Securities and Corporate Counsel AECOM 1999 Avenue of the Stars, Suite 2600 Los Angeles, CA 90067 Re: AECOM Registration Statement on Form S-4 Filed July 6 , 201 5 File No. 333-205512 Dear Mr. Szurgot : 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 1933 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 registrati on 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 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 46 1 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 un der Charles Szurgot AECOM July 9, 2015 Page 2 the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities. You may contact David Korvin at 202 -551-3236 or me at 202 -551-3397 with any questions. Sincerely, /s/ Jay Ingram Jay Ingram Legal Branch Chief cc: Via E -Mail Peter Wardle , Esq. Gibson, Dunn & Crutcher LLP