SEC Comment Letter for UPBOUND GROUP, INC. (UPBD) (CIK 0000933036) (UPBD) — Mar 10, 2011
UPBOUND GROUP, INC. (UPBD) (CIK 0000933036)
Date: March 10, 2011 · CIK: 0000933036 · Accession: 0000000000-11-015092
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-171867
Referenced dates: February 16, 2011
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE March 11, 2011 Via U.S. mail Dawn M. Wolverton, Esq. Vice President – Associate General Counsel and Assistant Secretary Rent-A-Center, Inc. 5501 Headquarters Drive Plano, Texas 75024
Re: Rent-A-Center, Inc. Registration Statement on Form S-4/A Filed March 8, 2011 File No. 333-171867
Dear Ms. Wolverton: We have reviewed the above-captioned f iling and have the following comments. General
1. We note your response to comment two of our letter dated February 16, 2011, however it is not apparent how you concl uded that your filing is compliant with Rule 3-10 of Regulation S-X. Please provide a detailed supporting analysis citing relevant regulatory guidance. Refe r generally to SEC Release 33-7878 (Aug. 15, 2000).
2. We reissue comment eight of our letter dated February 16, 2011. Please either remove the disclosure that references statements “within the meaning of the Section 27A of the Securities Act and Section 21E of the Exchange Act” or include express disclosure that states that the safe harbor prot ections contained in these sections does not apply to statements made in connection with this offering.
Exhibit 5.1
3. We object to the statement in the last sentence of the second paragraph. Please either delete counsel’s assumption rela ting to due authori zation, delivery and execution of the Indenture by the Trustee or provide support for why the assumption is appropriate and/or not readily ascertainable by Fulbright & Jaworski LLP.
Ms Dawn Wolverton Rent-A-Center, Inc. March 11, 2011 Page 2
You may contact me at (202) 551-3397 with any questions.
Sincerely,
Jay E. Ingram Legal Branch Chief
cc: James R. Griffin, Esq.
Fulbright & Jaworksi LLP
via facsimile at (214) 855-8200
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
March 11, 2011
Via U.S. mail
Dawn M. Wolverton, Esq. Vice President – Associate General Counsel and Assistant Secretary
Rent-A-Center, Inc. 5501 Headquarters Drive Plano, Texas 75024
Re: Rent-A-Center, Inc.
Registration Statement on Form S-4/A Filed March 8, 2011
File No. 333-171867
Dear Ms. Wolverton: We have reviewed the above-captioned f iling and have the following comments.
General
1. We note your response to comment two of our letter dated February 16, 2011,
however it is not apparent how you concl uded that your filing is compliant with
Rule 3-10 of Regulation S-X. Please provide a detailed supporting analysis citing
relevant regulatory guidance. Refe r generally to SEC Release 33-7878 (Aug. 15,
2000).
2. We reissue comment eight of our letter dated February 16, 2011. Please either
remove the disclosure that references statements “within the meaning of the
Section 27A of the Securities Act and Section 21E of the Exchange Act” or include express disclosure that states that the safe harbor prot ections contained in
these sections does not apply to statements made in connection with this offering.
Exhibit 5.1
3. We object to the statement in the last sentence of the second paragraph. Please
either delete counsel’s assumption rela ting to due authori zation, delivery and
execution of the Indenture by the Trustee or provide support for why the
assumption is appropriate and/or not readily ascertainable by Fulbright &
Jaworski LLP.
Ms Dawn Wolverton
Rent-A-Center, Inc. March 11, 2011
Page 2
You may contact me at (202) 551-3397 with any questions.
Sincerely,
Jay E. Ingram Legal Branch Chief
cc: James R. Griffin, Esq.
Fulbright & Jaworksi LLP
via facsimile at (214) 855-8200