SEC Company Response from AECOM (ACM) — Sep 15, 2014
AECOM
Date: Sept. 15, 2014 · CIK: 0000868857 · Accession: 0001104659-14-066239
AI Filing Summary & Sentiment
File numbers found in text: 333-197822
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 1 Station Place, N.E., Stop 7010 Washington, D.C. 20549 Re: AECOM Technology Corporation Registration Statement on Form S-4 File No. 333-197822 Acceleration Request
Dear Mr. Ingram:
Pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, AECOM Technology Corporation (the “Company”) hereby respectfully requests that the above-referenced Registration Statement on Form S-4 be declared effective as of 11:00 a.m., Washington, D.C. time, on September 17, 2014, or as soon thereafter as is practicable.
The Company hereby acknowledges 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 contact Peter W. Wardle at (213) 229-7242 of Gibson, Dunn & Crutcher LLP with any questions you may have concerning this request, and please notify him when this request for acceleration has been granted.
Very truly yours,
/s/ David Y. Gan
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CORRESP 1 filename1.htm AECOM 1999 Avenue of the Stars Suite 2600 Los Angeles, CA 90067 www.aecom.com 213.593.8000 213.593.8730 tel fax September 15, 2014 VIA EDGAR Jay Ingram Legal Branch Chief Securities and Exchange Commission Division of Corporation Finance 1 Station Place, N.E., Stop 7010 Washington, D.C. 20549 Re: AECOM Technology Corporation Registration Statement on Form S-4 File No. 333-197822 Acceleration Request Dear Mr. Ingram: Pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, AECOM Technology Corporation (the “Company”) hereby respectfully requests that the above-referenced Registration Statement on Form S-4 be declared effective as of 11:00 a.m., Washington, D.C. time, on September 17, 2014, or as soon thereafter as is practicable. The Company hereby acknowledges 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 contact Peter W. Wardle at (213) 229-7242 of Gibson, Dunn & Crutcher LLP with any questions you may have concerning this request, and please notify him when this request for acceleration has been granted. Very truly yours, /s/ David Y. Gan David Y. Gan Senior Vice President and Assistant General Counsel cc: Michael S. Burke, President and Chief Executive Officer, AECOM Technology Corporation Jonathan K. Layne, Partner, Gibson, Dunn & Crutcher LLP 1