SEC Company Response from GLOBAL PARTNERS LP (GLP, GLP-PB) (CIK 0001323468) (GLP) — Jan 7, 2020
GLOBAL PARTNERS LP (GLP, GLP-PB) (CIK 0001323468)
Date: Jan. 7, 2020 · CIK: 0001323468 · Accession: 0001104659-20-001949
AI Filing Summary & Sentiment
File numbers found in text: 333-235687
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CORRESP 1 filename1.htm GLOBAL PARTNERS LP 800 South Street P.O. Box 9161. Waltham, MA 02454 ph: 781-894-8800 fx: 781-398-9000 January 7, 2020 Via EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Dan Morris Re: Request for Acceleration of Effectiveness of Registration Statement on Form S-4 (File No. 333-235687) (as amended, the “Registration Statement”) of Global Partners LP, GLP Finance Corp. and the Additional Registrants Listed in the Registration Statement (the “Registrants”) Ladies and Gentlemen: Pursuant to Rule 461 under the United States Securities Act of 1933, as amended, and on behalf of the Registrants, the Registrants hereby request that the effectiveness of the above-captioned Registration Statement be accelerated so that such Registration Statement will become effective on January 10, 2020, at 10:00 a.m., Eastern Time, or as soon thereafter as practicable. The Registrants hereby acknowledge that the disclosure in the Registration Statement is the responsibility of the Registrants. The Registrants hereby further acknowledge that: · should the United States Securities and Exchange Commission (the “Commission”) or the staff (the “Staff”) thereof, 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 Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and · the Registrants 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 call Brenda Lenahan of Vinson & Elkins L.L.P. at (212) 237-0133 with any questions regarding this matter. Very truly yours, GLOBAL PARTNERS LP By: GLOBAL GP LLC its General Partner By: /s/ Edward J. Faneuil Edward J. Faneuil Executive Vice President and General Counsel GLP FINANCE CORP. By: /s/ Edward J. Faneuil Edward J. Faneuil Executive Vice President and General Counsel cc: Brenda Lenahan, Vinson & Elkins L.L.P. Signature Page to Acceleration Request Letter