SEC Company Response from NeueHealth, Inc. (CIK 0001671284) (NEUE) — Jun 21, 2021
NeueHealth, Inc. (CIK 0001671284)
Date: June 21, 2021 · CIK: 0001671284 · Accession: 0001104659-21-083414
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File numbers found in text: 333-256286
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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 21, 2021
Re: Acceleration Request for Bright Health Group, Inc.
Registration Statement on Form S-1 (File No. 333-256286)
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Eric Envall
J. Nolan McWilliams
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of
1933, as amended, we attach the requests of our client, Bright Health Group, Inc., and of the underwriters that effectiveness of the above-referenced
Registration Statement be accelerated to 4:00 p.m., Eastern Time, on June 23, 2021, or as soon as practicable thereafter. We ask, however,
that the Securities and Exchange Commission staff not accelerate such effectiveness until we speak with you on that date.
Please do not hesitate to call William Brentani
at (650) 251-5110 or Hui Lin at (212) 455-7862 with any questions.
Very truly yours,
/s/ William B. Brentani
William B. Brentani
New York
BEIJING
HONG KONG
Houston
LONDON
Los Angeles
SÃO PAULO
TOKYO
Washington, D.C.
June 21, 2021
VIA EDGAR
Re: Bright Health Group, Inc.
Registration Statement on Form S-1
File No. 333-256286
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Eric Envall
J. Nolan McWilliams
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of
1933, as amended (the “Securities Act”), Bright Health Group, Inc. (the “Company”) hereby requests that the effective
date of the above-referenced Registration Statement be accelerated so that it may become effective at 4:00 p.m., Eastern Time, on June
23, 2021, or as soon as possible thereafter. In this regard, the Company is aware of its obligations under the Securities Act.
If you require any additional information
with respect to this letter, please contact William Brentani (650-251-5110) or Hui Lin (212-455-7862) of Simpson Thacher & Bartlett
LLP.
[Signature Page Follows]
Very truly yours,
BRIGHT HEALTH GROUP, INC.
By:
/s/ Keith Nelsen
Name: Keith Nelsen
Title: General Counsel and Corporate Secretary
[Signature Page to Acceleration Request]
June 21, 2021
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Eric Envall
J. Nolan McWilliams
Re: Bright Health Group, Inc.
Registration Statement on Form S-1
Registration No. 333-256286
Acceleration Request
Requested Date: June 23, 2021
Requested Time: 4:00 PM, Eastern Time
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities
Act of 1933, as amended (the “Act”), J.P. Morgan Securities LLC, Goldman Sachs & Co. LLC, Morgan Stanley
& Co. LLC and Barclays Capital Inc., as representatives of the several underwriters, hereby join Bright Health Group, Inc. in requesting
that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the Registration
Statement on Form S-1 (File No. 333-256286) (the “Registration Statement”) to become effective on June 23, 2021,
at 4:00 PM, Eastern Time, or as soon as practicable thereafter.
Pursuant to Rule 460 under the Act, please be advised
that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to underwriters, dealers, institutions
and others, prior to the requested effective time of the Registration Statement.
We have been informed by the participating underwriters
that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, to the extent applicable.
[Signature Page Follows]
Very truly yours,
J.P. Morgan Securities LLC
By:
/s/ Alejandra Fernandez
Name: Alejandra Fernandez
Title: Executive Director
Goldman Sachs & Co. LLC
By:
/s/ Dan Cocks
Name: Dan Cocks
Title: Managing Director, ECM
Morgan Stanley & Co. LLC
By:
/s/ Kalli Dircks
Name: Kalli Dircks
Title: Managing Director
Barclays Capital Inc.
By:
/s/ Victoria Hale
Name: Victoria Hale
Title: Authorized Signatory
cc: Keith Nelsen, Bright Health Group, Inc.
Bradley C. Weber, Goodwin Procter LLP
Gregg L. Katz, Goodwin Procter LLP
Kim S. de Glossop, Goodwin Procter LLP
William B. Brentani, Simpson Thacher & Bartlett
LLP
Xiaohui (Hui) Lin, Simpson Thacher & Bartlett
LLP
[Signature Page to Acceleration
Request]