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SEC Company Response from RB GLOBAL INC. (RBA) (CIK 0001046102) (RBA) — Dec 20, 2012

RB GLOBAL INC. (RBA) (CIK 0001046102)
Date: Dec. 20, 2012 · CIK: 0001046102 · Accession: 0001193125-12-511045

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File numbers found in text: 001-13425

Referenced dates: December 13, 2012

Date
December 20, 2012
Author
/s/ Robert A. McLeod
Form
CORRESP
Company
RB GLOBAL INC. (RBA) (CIK 0001046102)

Letter

VIA EDGAR SUBMISSION United States Securities and Exchange Commission Division of Corporation Finance Re: Ritchie Bros. Auctioneers Incorporated Form 40-F for the Fiscal Year Ended December 31, 2011 Filed February 28, 2012 File No. 001-13425

Dear Mr. Gilmore:

We are in receipt of your comment letter dated December 13, 2012, regarding Ritchie Bros. Auctioneers Inc.’s February 28, 2012 Form 40-F. As discussed with Jennifer Fugario, we are requesting an additional 10 business days to respond due to time constraints associated with the holiday break and our fiscal year end, which would result in us submitting our response letter by January 14, 2013. Please confirm if this is acceptable.

Very truly yours,
/s/ Robert A. McLeod

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Correspondence

 Ritchie Bros. Auctioneers Incorporated

9500 Glenlyon Parkway, Burnaby, BC Canada V5J 0C6

 Tel: 778-331-5500 • Fax: 778-331-4628

 rbauction.com

 December 20, 2012

 VIA EDGAR SUBMISSION

 Patrick Gilmore

Accounting Branch Chief

 United States
Securities and Exchange Commission

 Division of Corporation Finance

 Washington, D.C 20549

 Re: Ritchie Bros. Auctioneers Incorporated

Form 40-F for the Fiscal Year Ended December 31, 2011

 Filed February 28, 2012

 File No. 001-13425

Dear Mr. Gilmore:

 We are in receipt of
your comment letter dated December 13, 2012, regarding Ritchie Bros. Auctioneers Inc.’s February 28, 2012 Form 40-F. As discussed with Jennifer Fugario, we are requesting an additional 10 business days to respond due to time constraints
associated with the holiday break and our fiscal year end, which would result in us submitting our response letter by January 14, 2013. Please confirm if this is acceptable.

 Very truly yours,

 /s/ Robert A. McLeod

 Robert A. McLeod

 Chief Financial Officer

 Ritchie Bros. Auctioneers