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SEC Company Response from AECOM (ACM) — Sep 28, 2015

AECOM
Date: Sept. 28, 2015 · CIK: 0000868857 · Accession: 0001104659-15-067737

AI Filing Summary & Sentiment

File numbers found in text: 333-205512

Date
September 28, 2015
Author
/s/ Keenan Edward Driscoll
Form
CORRESP
Company
AECOM

Letter

AECOM

213.593.8100

tel

1999 Avenue of the Stars

213.593.8178

fax

Suite 2600

Los Angeles, CA 90067

www.aecom.com

September 28, 2015

VIA EDGAR AND ELECTRONIC MAIL

United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: AECOM Registration Statement on Form S-4 (File No. 333-205512)

Ladies and Gentlemen:

This letter is sent in connection with the above-referenced Registration Statement on Form S-4 (File No. 333-205512) (the “Registration Statement”) filed with the Securities and Exchange Commission (the “Commission”) by AECOM and the other co-registrants referenced therein (collectively, the “Company”) pursuant to the Securities Act of 1933, as amended (the “Securities Act”). Pursuant to Rule 461 promulgated under the Securities Act, the Company hereby respectfully requests that the effective time of the Registration Statement be accelerated to 4:00 p.m., Eastern Time, on September 29, 2015 or as soon thereafter as practicable.

The Company hereby acknowledges that:

· should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

· the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; 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.

Should you have any questions regarding this request, please contact Peter Wardle of Gibson, Dunn & Crutcher LLP at (213) 229-7242.

Very truly yours,
/s/ Keenan Edward Driscoll

Show Raw Text
CORRESP
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AECOM

213.593.8100

tel

1999   Avenue of the Stars

213.593.8178

fax

Suite 2600

Los   Angeles, CA 90067

www.aecom.com

September 28, 2015

VIA EDGAR AND ELECTRONIC MAIL

United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

Re:                          AECOM
 Registration Statement on Form S-4 (File No. 333-205512)

Ladies and Gentlemen:

This letter is sent in connection with the above-referenced Registration Statement on Form S-4 (File No. 333-205512) (the “Registration Statement”) filed with the Securities and Exchange Commission (the “Commission”) by AECOM and the other co-registrants referenced therein (collectively, the “Company”) pursuant to the Securities Act of 1933, as amended (the “Securities Act”).  Pursuant to Rule 461 promulgated under the Securities Act, the Company hereby respectfully requests that the effective time of the Registration Statement be accelerated to 4:00 p.m., Eastern Time, on September 29, 2015 or as soon thereafter as practicable.

The Company hereby acknowledges that:

·                  should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

·                  the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; 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.

Should you have any questions regarding this request, please contact Peter Wardle of Gibson, Dunn & Crutcher LLP at (213) 229-7242.

Very truly yours,

/s/ Keenan Edward Driscoll

Keenan   Edward Driscoll

Authorized   Officer of AECOM and Co-Registrants

cc:                              Peter Wardle, Gibson, Dunn & Crutcher LLP