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SEC Company Response from Surgery Partners, Inc. (SGRY) (CIK 0001638833) (SGRY) — Sep 29, 2015

Surgery Partners, Inc. (SGRY) (CIK 0001638833)
Date: Sept. 29, 2015 · CIK: 0001638833 · Accession: 0001193125-15-331876

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File numbers found in text: 333-206439

Date
September 30, 2015
Author
Michael T. Doyle
Form
CORRESP
Company
Surgery Partners, Inc. (SGRY) (CIK 0001638833)

Letter

Acceleration Request

SURGERY PARTNERS, INC.

40 Burton Hills Boulevard

Suite

Nashville, TN 37215

September 29,

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Re: Surgery Partners, Inc.

Registration Statement on Form S-1 (File No. 333-206439)

Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Surgery Partners, Inc. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-206439), as amended (the “Registration Statement”), so that it will be declared effective at 4:00 p.m. Eastern Time on September 30, 2015, or as soon as possible thereafter. The Company hereby authorizes Carl Marcellino of Ropes & Gray LLP, counsel to the Company, to orally modify or withdraw this request for acceleration.

The Company hereby acknowledges that:

(i) should the Securities and Exchange Commission (the “Commission”) or the staff, 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;

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

(iii) it is the staff’s position that the Company may not assert staff comments and the declaration of effectiveness of the Registration statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

U.S. Securities and Exchange Commission

Page

Please notify Carl Marcellino of Ropes & Gray LLP, counsel to the Company, at (212) 841-0623 as soon as the Registration Statement has been declared effective.

Very truly yours,
SURGERY PARTNERS, INC.

Show Raw Text
CORRESP
1
filename1.htm

Acceleration Request

 SURGERY PARTNERS, INC.

40 Burton Hills Boulevard

 Suite
500

 Nashville, TN 37215

 September 29,
2015

 VIA EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 100 F. Street,
N.E.

 Washington, D.C. 20549

Re:
Surgery Partners, Inc.

Registration Statement on Form S-1 (File No. 333-206439)

Request for Acceleration

 Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Surgery Partners, Inc. (the “Company”) hereby
requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-206439), as amended (the “Registration Statement”), so that it will be declared effective at 4:00 p.m. Eastern Time on
September 30, 2015, or as soon as possible thereafter. The Company hereby authorizes Carl Marcellino of Ropes & Gray LLP, counsel to the Company, to orally modify or withdraw this request for acceleration.

The Company hereby acknowledges that:

(i)
should the Securities and Exchange Commission (the “Commission”) or the staff, 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;

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

(iii)
it is the staff’s position that the Company may not assert staff comments and the declaration of effectiveness of the Registration statement as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

 U.S. Securities and Exchange Commission

 Page
 2

 Please notify Carl Marcellino of Ropes & Gray LLP, counsel to the Company, at
(212) 841-0623 as soon as the Registration Statement has been declared effective.

 Very truly yours,

SURGERY PARTNERS, INC.

By:

/s/ Michael T. Doyle

Michael T. Doyle

Chief Executive Officer