SEC Company Response from NeueHealth, Inc. (CIK 0001671284) (NEUE) — Jun 15, 2021
NeueHealth, Inc. (CIK 0001671284)
Date: June 15, 2021 · CIK: 0001671284 · Accession: 0001104659-21-081210
AI Filing Summary & Sentiment
File numbers found in text: 333-256286
Referenced dates: June 10, 2021
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CORRESP
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filename1.htm
Simpson Thacher & Bartlett llp
425
lexington avenue
new
york, ny 10017-3954
telephone:
+1-212-455-2000
facsimile:
+1-212-455-2502
Direct Dial
Number
(650) 251-5110
(212) 455-7862
E-mail
Address
wbrentani@stblaw.com
hui.lin@stblaw.com
VIA EDGAR
June 15, 2021
Re: Bright Health Group, Inc.
Registration Statement on Form S-1Filed June 15, 2021
CIK No. 0001671284
Eric Envall
J. Nolan McWilliams
Mark Brunhofer
Sharon Blume
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Ladies and Gentlemen:
On behalf of Bright Health Group, Inc. (the
“Company”), we hereby transmit via EDGAR for filing under the Securities Act of 1933, as amended, Amendment No. 2 to the
Registration Statement on Form S-1 (Form No. 333-256286) (the “Registration Statement”) relating to the proposed
offering of the Company’s common stock. The Company has revised the Registration Statement to reflect changes in the sections
entitled “Summary Historical and Pro Forma Consolidated Financial and Other Data,” “Capitalization,”
“Dilution,” and “Management’s Discussion and Analysis of Financial Condition and Results of
Operations” and the Company’s unaudited condensed consolidated financial statements, in each case, in response to oral
comments from the staff on June 11, 2021, as well as to provide certain other updates with respect to the offering and the Company,
including changes previously provided to the staff of the via a correspondence letter dated June 10, 2021.
* * * * * * *
Securities and Exchange Commission -2- June 15, 2021
Please do not hesitate to call William Brentani
at (650) 251-5110 or Hui Lin at (212) 455-7862 with any questions or further comments regarding this submission or if you wish to discuss
any of the above responses.
Very truly yours,
/s/ Simpson Thacher & Bartlett LLP
Simpson Thacher & Bartlett LLP
cc: Bright Health Group, Inc.
G. Mike Mikan
Catherine R. Smith
Keith Nelsen
Goodwin Procter LLP
Bradley C. Weber
Gregg L. Katz
Kim S. de Glossop