SEC Company Response from VALVOLINE INC (VVV) (CIK 0001674910) (VVV) — Sep 20, 2016
VALVOLINE INC (VVV) (CIK 0001674910)
Date: Sept. 20, 2016 · CIK: 0001674910 · Accession: 0001193125-16-714858
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-211720
Letter
Via EDGAR United States Securities and Exchange Commission Division of Corporation Finance September 20, 2016 Valvoline Inc. Registration Statement on Form S-1 File No. 333-211720
Dear Mr. Slivka:
Pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the “Securities Act”), Valvoline Inc., a corporation organized and existing under the laws of the Commonwealth of Kentucky (the “Company”), hereby requests that the effective date of the above-referenced Registration Statement be accelerated so that the Registration Statement, as then amended, will become effective under the Securities Act by 4:00 p.m., New York City time, on September 22, 2016, or as soon thereafter as practicable.
In connection with this request, the Company acknowledges that:
•
should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
•
the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
•
the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
* * *
It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform the Company’s counsel, Andrew J. Pitts of Cravath, Swaine & Moore LLP at (212) 474-1620, and then send written confirmation to the addressees listed on the cover of the Registration Statement.
Very truly yours,
Valvoline Inc.
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CORRESP
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CORRESP
Valvoline Inc.
3499 Blazer Parkway
Lexington, KY
40509
(859) 357-7777
Via EDGAR
United States Securities and Exchange Commission
Division of
Corporation Finance
100 F Street, N.E.
Washington, D.C.
20549-7010
Attn:
Mr. Craig Slivka
Mr. Terence O’Brien
Ms. Tracie Mariner
Mr. David Korvin
September 20, 2016
Valvoline Inc.
Registration Statement on Form S-1
File No. 333-211720
Dear
Mr. Slivka:
Pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission (the
“Commission”) under the Securities Act of 1933, as amended (the “Securities Act”), Valvoline Inc., a corporation organized and existing under the laws of the Commonwealth of Kentucky (the
“Company”), hereby requests that the effective date of the above-referenced Registration Statement be accelerated so that the Registration Statement, as then amended, will become effective under the Securities Act by 4:00 p.m., New
York City time, on September 22, 2016, or as soon thereafter as practicable.
In connection with this request, the Company
acknowledges that:
•
should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;
•
the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and
•
the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
* * *
It would be appreciated if, as soon as the Registration Statement is declared effective, you
would so inform the Company’s counsel, Andrew J. Pitts of Cravath, Swaine & Moore LLP at (212) 474-1620, and then send written confirmation to the addressees listed on the cover of the Registration Statement.
Very truly yours,
Valvoline Inc.
By:
/s/ Julie M. O’Daniel
Julie M. O’Daniel
General Counsel and Secretary