SEC Comment Letter for VALVOLINE INC (VVV) (CIK 0001674910) (VVV) — Nov 21, 2017
VALVOLINE INC (VVV) (CIK 0001674910)
Date: Nov. 21, 2017 · CIK: 0001674910 · Accession: 0000000000-17-041191
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Reasoning
File numbers found in text: 333-221652
Letter
Mail Stop 4631 November 21, 2017 Julie M. O’Daniel Senior Vice President, General Counsel & Corporate Secretary Valvoline Inc. 100 Valvoline Way Lexington, KY 40509
Re: Valvoline Inc. Registration Statement on Form S-4 Filed November 17, 2017 File No. 333-221652
Dear Ms. O’Daniel :
This is to advise you that we have not reviewed and will not review your registration statement .
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact Sergio Chinos, Staff Attorney, at (202) 551 -7844 with any questions.
Sincerely,
/s/ Jay Ingram
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Mail Stop 4631 November 21, 2017 Julie M. O’Daniel Senior Vice President, General Counsel & Corporate Secretary Valvoline Inc. 100 Valvoline Way Lexington, KY 40509 Re: Valvoline Inc. Registration Statement on Form S-4 Filed November 17, 2017 File No. 333-221652 Dear Ms. O’Daniel : This is to advise you that we have not reviewed and will not review your registration statement . Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Sergio Chinos, Staff Attorney, at (202) 551 -7844 with any questions. Sincerely, /s/ Jay Ingram Jay Ingram Legal Branch Chief Office of Manufacturing and Construction cc: Ilir Mujalovic, Esq.