SEC Company Response from BRIGHT HORIZONS FAMILY SOLUTIONS INC. (BFAM) (CIK 0001437578) (BFAM) — Apr 2, 2013
BRIGHT HORIZONS FAMILY SOLUTIONS INC. (BFAM) (CIK 0001437578)
Date: April 2, 2013 · CIK: 0001437578 · Accession: 0001193125-13-138814
AI Filing Summary & Sentiment
Reasoning
Letter
Correspondence
ROPES & GRAY LLP
PRUDENTIAL TOWER
800 BOYLSTON STREET
BOSTON, MA 02199-3600
WWW.ROPESGRAY.COM
August 30, 2012
Confidential Submission
Pursuant to Title I, Section 106 under
the Jumpstart Our Business Startups
Act and
Section 24(b)(2) of the
Securities Exchange Act of 1934
EMAILED TO CFDRAFT.SUBMISSION@SEC.GOV
VIA SEC SECURE EMAIL PORTAL
CONFIDENTIAL SUBMISSION
Draft Registration Statement
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Bright Horizons Family Solutions Inc.
Confidential Submission of Draft Registration Statement on Form S-1
Ladies and Gentlemen:
On behalf of Bright Horizons Family Solutions Inc., a Delaware corporation (the “Company”), and in connection with the confidential submission of its draft registration statement on Form S-1 (the “Registration Statement”) on the date hereof, we hereby confidentially submit the draft Registration Statement pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act (the “JOBS Act”) and Section 24(b)(2) of the Securities Exchange Act of 1934, as amended, for non-public review by the Staff of the Securities and Exchange Commission (the “Commission”) prior to the public filing of the Registration Statement. A copy of the Registration Statement has been submitted along with this letter to cfdraft.submission@sec.gov through the SEC Secure Email Portal (https://web1.zixmail.net/s/welcome.jsp?b=sec).
Pursuant to Title 1, Section 101 of the JOBS Act, the Company is an “emerging growth company” that had total annual gross revenues of less than $1.0 billion during its most recently completed fiscal year ended December 31, 2011. Therefore, the Company is permitted to make this confidential submission of the Registration Statement for review by the Staff, provided that the Registration Statement and all amendments thereto shall be publicly filed with the Commission not later than 21 days before the date on which the Company conducts a “road show,” as such term is defined in Title 17, Section 230.433(h)(4) of the Code of Federal Regulations. In addition, as an “emerging growth company,” the Company has omitted certain disclosures required by Form S-1 in accordance with the provisions of Title 1 of the JOBS Act, including certain compensation information.
- -
August 30, 2012
Please direct all notices and communications with respect to this confidential submission to each of the following:
John G. Casagrande
General Counsel
200 Talcott Avenue South
Watertown, Massachusetts 02472
Telephone: (617) 673-8000
Facsimile: (617) 673-8629
With a copy to:
Craig E. Marcus
Ropes & Gray LLP
Prudential Tower
Boylston Street
Boston, Massachusetts
Telephone: (617) 951-7000
Facsimile: (617) 951-7050
Alternatively, please feel free to contact me at (617) 235-4734 or rachel.phillips@ropesgray.com if you have any questions regarding this submission.
Very truly yours,
/s/ Rachel Phillips
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CORRESP 1 filename1.htm Correspondence ROPES & GRAY LLP PRUDENTIAL TOWER 800 BOYLSTON STREET BOSTON, MA 02199-3600 WWW.ROPESGRAY.COM August 30, 2012 Confidential Submission Pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act and Section 24(b)(2) of the Securities Exchange Act of 1934 EMAILED TO CFDRAFT.SUBMISSION@SEC.GOV VIA SEC SECURE EMAIL PORTAL CONFIDENTIAL SUBMISSION Draft Registration Statement United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Bright Horizons Family Solutions Inc. Confidential Submission of Draft Registration Statement on Form S-1 Ladies and Gentlemen: On behalf of Bright Horizons Family Solutions Inc., a Delaware corporation (the “Company”), and in connection with the confidential submission of its draft registration statement on Form S-1 (the “Registration Statement”) on the date hereof, we hereby confidentially submit the draft Registration Statement pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act (the “JOBS Act”) and Section 24(b)(2) of the Securities Exchange Act of 1934, as amended, for non-public review by the Staff of the Securities and Exchange Commission (the “Commission”) prior to the public filing of the Registration Statement. A copy of the Registration Statement has been submitted along with this letter to cfdraft.submission@sec.gov through the SEC Secure Email Portal (https://web1.zixmail.net/s/welcome.jsp?b=sec). Pursuant to Title 1, Section 101 of the JOBS Act, the Company is an “emerging growth company” that had total annual gross revenues of less than $1.0 billion during its most recently completed fiscal year ended December 31, 2011. Therefore, the Company is permitted to make this confidential submission of the Registration Statement for review by the Staff, provided that the Registration Statement and all amendments thereto shall be publicly filed with the Commission not later than 21 days before the date on which the Company conducts a “road show,” as such term is defined in Title 17, Section 230.433(h)(4) of the Code of Federal Regulations. In addition, as an “emerging growth company,” the Company has omitted certain disclosures required by Form S-1 in accordance with the provisions of Title 1 of the JOBS Act, including certain compensation information. - 2 - August 30, 2012 Please direct all notices and communications with respect to this confidential submission to each of the following: John G. Casagrande General Counsel 200 Talcott Avenue South Watertown, Massachusetts 02472 Telephone: (617) 673-8000 Facsimile: (617) 673-8629 With a copy to: Craig E. Marcus Ropes & Gray LLP Prudential Tower 800 Boylston Street Boston, Massachusetts Telephone: (617) 951-7000 Facsimile: (617) 951-7050 Alternatively, please feel free to contact me at (617) 235-4734 or rachel.phillips@ropesgray.com if you have any questions regarding this submission. Very truly yours, /s/ Rachel Phillips Attachment cc: John Casagrande, Bright Horizons Family Solutions Inc. Elizabeth Boland, Bright Horizons Family Solutions Inc. Craig E. Marcus, Ropes & Gray LLP D. Rhett Brandon, Simpson Thacher & Bartlett LLP John Ericson, Simpson Thacher & Bartlett LLP