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SEC Company Response from Thryv Holdings, Inc. (THRY) (CIK 0001556739) (THRY) — Jan 31, 2013

Thryv Holdings, Inc. (THRY) (CIK 0001556739)
Date: Jan. 31, 2013 · CIK: 0001556739 · Accession: 0001193125-13-032678

AI Filing Summary & Sentiment

File numbers found in text: 333-185348

Date
January 31, 2013
Author
/s/ Mark W.
Form
CORRESP
Company
Thryv Holdings, Inc. (THRY) (CIK 0001556739)

Letter

Correspondence

[Dex One letterhead]

January 31, 2013

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549

Attention: Mr. Larry Spirgel, Assistant Director

Re: Newdex, Inc.

Registration Statement on Form S-4

File No. 333-185348

This letter is submitted in connection with Newdex, Inc.’s (“Newdex,” the “Company,” “we,” “us” and “our”) Amendment No. 2 (the “Amendment”) to the Company’s Registration Statement on Form S-4 initially filed by the Company on December 7, 2012 (the “Registration Statement”) in response to a comment by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) during a teleconference on January 23, 2013.

* * * * * *

The Company acknowledges that:

•

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Company 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.

We have provided this response letter to you via facsimile, as well as through EDGAR submission, to facilitate an expeditious resolution to any remaining comments the Staff may have.

Division of Corporation Finance

January 31, 2013

Page 2 of 2

Dex One and SuperMedia would like to hold their special meetings as soon as possible and, therefore, the Company would appreciate the Staff’s expedited review of the Amendment.

Please contact me at (919) 297-1222 should you wish to discuss any of the Company’s responses. Thank you for your continuing attention to this matter.

Sincerely,
/s/ Mark W.
Hianik

Show Raw Text
CORRESP
1
filename1.htm

Correspondence

 [Dex One letterhead]

 January 31, 2013

 Division of Corporation Finance

Securities and Exchange Commission

 100 F Street
N.E.

 Washington, DC 20549

Attention: Mr. Larry Spirgel, Assistant Director

Re:
Newdex, Inc.

Registration Statement on Form S-4

File No. 333-185348

 This letter is
submitted in connection with Newdex, Inc.’s (“Newdex,” the “Company,” “we,” “us” and “our”) Amendment No. 2 (the “Amendment”) to the Company’s Registration Statement on Form
S-4 initially filed by the Company on December 7, 2012 (the “Registration Statement”) in response to a comment by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) during a
teleconference on January 23, 2013.

 * * * * * *

 The Company acknowledges that:

•

 should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from
taking any action with respect to the filing;

•

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from
its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

 the Company 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.

 We have provided this response letter to you via facsimile, as well
as through EDGAR submission, to facilitate an expeditious resolution to any remaining comments the Staff may have.

 Division of Corporation Finance

 January 31, 2013

 Page 2 of 2

 Dex One and SuperMedia would like to hold their special meetings as soon as possible and, therefore, the Company would appreciate the Staff’s expedited review of the Amendment.

Please contact me at (919) 297-1222 should you wish to discuss any of the Company’s responses. Thank you for your continuing attention to this
matter.

 Sincerely,

 /s/ Mark W.
Hianik

 Mark W. Hianik

 cc:

 Claire DeLabar, Staff Accountant

Terry French, Accountant Branch Chief

 Brandon
Hill, Attorney-Advisor

 Celeste M. Murphy, Legal Branch Chief