SEC Company Response from AECOM (ACM) — May 7, 2007
AECOM
Date: May 7, 2007 · CIK: 0000868857 · Accession: 0001104659-07-036412
AI Filing Summary & Sentiment
File numbers found in text: 333-141142
Letter
Securities and Exchange Commission Washington, D.C. 20549 Attention: Karen J. Garnett Re: AECOM Technology Corporation Registration Statement on Form S-1 (File No. 333-141142)
Dear Ms Garnett:
AECOM Technology Corporation, a Delaware corporation (the “Company”), respectfully requests pursuant to Rule 461 under the Securities Act of 1933, as amended, that the effective date of the Company’s Registration Statement on Form S-1 (File No. 333-141142) (the “Filing”) be accelerated and that it be declared effective May 9, 2007 at 2:00 p.m. Eastern time, or as soon as practicable thereafter.
Further, the Company acknowledges:
· Should the Commission or the staff of the Commission (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 accuracy and adequacy of the disclosure of the Filing; and
· The Company may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
It is the Company’s understanding that its registration of the common stock of the Company under the Securities Exchange Act of 1934 on Form 8-A (File No. ) shall automatically become effective upon the later of the Commission’s receipt of certification from the New York Stock Exchange regarding the common stock of the Company and the effectiveness of the Filing.
Please contact the undersigned at (213) 593-8719, or Jonathan K. Layne of Gibson, Dunn & Crutcher LLP at (310) 552-8641, with any questions you may have regarding this letter or the Filing.
Very truly yours,
/s/ Eric Chen
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AECOM
555 South Flower Street, 37th Floor
Los Angeles, CA 90071-2300
T 213.593.8000 F 213.593.8730 www.aecom.com
May 7, 2007
VIA FACSIMILE AND EDGAR
Securities and Exchange
Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Karen J.
Garnett
Re: AECOM Technology Corporation
Registration Statement on Form S-1 (File No.
333-141142)
Dear Ms Garnett:
AECOM Technology Corporation, a Delaware corporation
(the “Company”), respectfully requests pursuant to Rule 461 under the
Securities Act of 1933, as amended, that the effective date of the Company’s
Registration Statement on Form S-1 (File No. 333-141142) (the “Filing”)
be accelerated and that it be declared effective May 9, 2007 at 2:00 p.m.
Eastern time, or as soon as practicable thereafter.
Further, the Company acknowledges:
· Should
the Commission or the staff of the Commission (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 accuracy and adequacy of the disclosure of the Filing;
and
· The
Company may not assert this action as defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United
States.
It is the Company’s understanding that its
registration of the common stock of the Company under the Securities Exchange
Act of 1934 on Form 8-A (File No. )
shall automatically become effective upon the later of the Commission’s receipt
of certification from the New York Stock Exchange regarding the common stock of
the Company and the effectiveness of the Filing.
Please contact the undersigned at (213) 593-8719, or
Jonathan K. Layne of Gibson, Dunn & Crutcher LLP at (310) 552-8641, with
any questions you may have regarding this letter or the Filing.
Very truly yours,
/s/ Eric Chen
Eric Chen
Senior Vice President, Finance and General Counsel
cc: Mr.
Michael McTiernan, United States Securities and Exchange Commission
John M. Dionisio, AECOM
Technology Corporation
Jonathan K. Layne, Gibson,
Dunn & Crutcher LLP
J. Scott Hodgkins, Latham
& Watkins LLP