SEC Comment Letter for VALVOLINE INC (VVV) (CIK 0001674910) (VVV) — Sep 2, 2016
VALVOLINE INC (VVV) (CIK 0001674910)
Date: Sept. 2, 2016 · CIK: 0001674910 · Accession: 0000000000-16-091332
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-2117
Letter
Mail Stop 4631 September 2 , 201 6 Via E -mail Peter Ganz Senior Vice President, General Counsel and Secretary Ashland Inc. 50 E. RiverCenter Boulevard P.O. Box 391 Covington, KY 41012
Re: Valvoline Inc. Amendment No. 3 to Registration Statement on Form S -1 Filed August 23 , 2016 File No. 333-2117 20
Dear Mr. Ganz :
We have reviewed your response letter and the above -referenced filing, and have the following comment.
Share Eligible for Future Sale, page 173 Directed Share Program, page 173
1. We note your disclosure that shares under the directed share program will be offered to “certain of our employees and certain other persons.” Please revise your disclosure to identify wi th more specificity the category of persons eligible to participate in the program. Additionally, please disclose whether these shares will be subject to the lock - up period.
You may contact Tracie Mariner , Staff Accountant at 202 -551-3744 or Terence O’Br ien, Accounting Branch Chief at 202 -551-3355 if you have questions regarding comments on the financial statements and related matters. Please contact David Korvin, Staff Attorney at 202 - 551-3236 or Craig Slivka, Special Counsel at 202 -551-3729 with any ot her questions.
Sincerely,
/S/ Craig S livka, for
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Mail Stop 4631 September 2 , 201 6 Via E -mail Peter Ganz Senior Vice President, General Counsel and Secretary Ashland Inc. 50 E. RiverCenter Boulevard P.O. Box 391 Covington, KY 41012 Re: Valvoline Inc. Amendment No. 3 to Registration Statement on Form S -1 Filed August 23 , 2016 File No. 333-2117 20 Dear Mr. Ganz : We have reviewed your response letter and the above -referenced filing, and have the following comment. Share Eligible for Future Sale, page 173 Directed Share Program, page 173 1. We note your disclosure that shares under the directed share program will be offered to “certain of our employees and certain other persons.” Please revise your disclosure to identify wi th more specificity the category of persons eligible to participate in the program. Additionally, please disclose whether these shares will be subject to the lock - up period. You may contact Tracie Mariner , Staff Accountant at 202 -551-3744 or Terence O’Br ien, Accounting Branch Chief at 202 -551-3355 if you have questions regarding comments on the financial statements and related matters. Please contact David Korvin, Staff Attorney at 202 - 551-3236 or Craig Slivka, Special Counsel at 202 -551-3729 with any ot her questions. Sincerely, /S/ Craig S livka, for Pamela Long Assistant Director Office of Manufacturing and Construction Peter Ganz Ashland Inc. September 2, 2016 Page 2 cc: Via E-mail Andrew Pitts Cravath, Swaine & Moore LLP