SEC Company Response from HERC HOLDINGS INC (HRI) (CIK 0001364479) (HRI) — Sep 21, 2006
HERC HOLDINGS INC (HRI) (CIK 0001364479)
Date: Sept. 21, 2006 · CIK: 0001364479 · Accession: 0001047469-06-011983
AI Filing Summary & Sentiment
File numbers found in text: 333-135782
Letter
Securities and Exchange Commission Division of Corporation Finance VIA EDGAR Re: Hertz Global Holdings, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed August 25, 2006 File No. 333-135782
Dear Ms. Kalin:
This letter sets forth the responses of Hertz Global Holdings, Inc. (the “Company”) to comment 18 (“Comment 18”) contained in your letter, dated September 13, 2006, relating to Amendment No. 1 to the Registration Statement on Form S-1 (the “Registration Statement”) of the Company filed with the Securities and Exchange Commission (the “Commission”) on August 25, 2006. The text of Comment 18 is set forth in bold/italicized type below, and the Company’s response is set forth in plain type immediately beneath such comment.
Enclosed with the paper copy of this letter are supplemental materials requested by the staff of the Commission (the “Staff”) or responsive to the Staff’s comments. Pursuant to Rule 418(b) promulgated under the Securities Act of 1933, as amended (“Rule 418(b)”), the supplemental information is being provided to the Staff on a supplemental, confidential basis only and is not to be filed with or deemed a part of Amendment No. 2 to the Registration Statement.
Pursuant to Rule 418(b), the Company hereby requests that the supplemental information be returned to the undersigned promptly following completion of the Staff’s review of the supplemental information.
The Company believes that the supplemental information contains information relating to its operations and market position, and that disclosure of this information could cause substantial competitive harm to the Company and is not necessary for the protection of investors.
Please call the undersigned when the Staff has completed its review and the Company will arrange to have the supplemental information retrieved. The Company respectfully reserves the right to have the supplemental information returned to the Company at an earlier date.
Hertz Holdings Stock Incentive Plan, page 87
18. We have reviewed your response to our prior comment number 52. Please note that we will revisit your response at the time that a range of offering prices is included in your registration statement.
The Company acknowledges the Staff’s comment, and notes for the Staff that it has supplementally provided with the paper copy of this letter as Annex 18 a preliminary range of offering prices, together with supplementary explanation responding to the Staff’s comments.
* * * * *
If you have any questions regarding this letter, please do not hesitate to call Steven Slutzky at (212) 909-6036, Lee Barnum at (212) 909-6431 or Kristine Hutchinson at (212) 909-6160.
Regards,
/s/ Steven J. Slutzky
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CORRESP
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filename1.htm
[Letterhead of Debevoise &
Plimpton LLP]
September 21, 2006
Ms. Sara D. Kalin
Branch Chief — Legal
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
Mail Stop 3561
VIA EDGAR
Re: Hertz Global Holdings, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed August 25, 2006
File No. 333-135782
Dear Ms. Kalin:
This letter sets forth the responses of Hertz Global
Holdings, Inc. (the “Company”) to comment 18 (“Comment 18”) contained in your
letter, dated September 13, 2006, relating to Amendment No. 1 to the
Registration Statement on Form S-1 (the “Registration Statement”) of the
Company filed with the Securities and Exchange Commission (the “Commission”) on
August 25, 2006. The text of Comment 18
is set forth in bold/italicized type below, and the Company’s response is set
forth in plain type immediately beneath such comment.
Enclosed with the paper copy of this letter are
supplemental materials requested by the staff of the Commission (the “Staff”)
or responsive to the Staff’s comments.
Pursuant to Rule 418(b) promulgated under the Securities Act of 1933, as
amended (“Rule 418(b)”), the supplemental information is being provided to the
Staff on a supplemental, confidential basis only and is not to be filed with or
deemed a part of Amendment No. 2 to the Registration Statement.
Pursuant to Rule 418(b), the Company hereby requests
that the supplemental information be returned to the undersigned promptly
following completion of the Staff’s review of the supplemental information.
The Company believes that the supplemental information
contains information relating to its operations and market position, and that
disclosure of this information could cause substantial competitive harm to the
Company and is not necessary for the protection of investors.
Please call the undersigned when the Staff has
completed its review and the Company will arrange to have the supplemental
information retrieved. The Company
respectfully reserves the right to have the supplemental information returned
to the Company at an earlier date.
Hertz Holdings Stock Incentive Plan, page 87
18. We have reviewed your
response to our prior comment number 52.
Please note that we will revisit your response at the time that a range
of offering prices is included in your registration statement.
The Company acknowledges the Staff’s comment, and
notes for the Staff that it has supplementally provided with the paper copy of
this letter as Annex 18 a preliminary range of offering prices, together with
supplementary explanation responding to the Staff’s comments.
* * * * *
If you have any questions regarding this letter,
please do not hesitate to call Steven Slutzky at (212) 909-6036, Lee
Barnum at (212) 909-6431 or Kristine Hutchinson at (212) 909-6160.
Regards,
/s/ Steven J. Slutzky
Steven J. Slutzky
cc: H. Yuna Peng
Jeffrey Sears
Michael Fay
Securities
and Exchange Commission
Mark P. Frissora
Paul J. Siracusa
Harold E. Rolfe, Esq.
Richard Foti
Hertz Global Holdings, Inc.
Enclosures
2