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SEC Company Response from ADT Inc. (ADT) (CIK 0001703056) (ADT) — Jan 7, 2020

ADT Inc. (ADT) (CIK 0001703056)
Date: Jan. 7, 2020 · CIK: 0001703056 · Accession: 0001193125-20-003295

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File numbers found in text: 333-235331

Date
January 7, 2020
Author
Jeffrey Likosar
Form
CORRESP
Company
ADT Inc. (ADT) (CIK 0001703056)

Letter

VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Attention: Mr. Scott Anderegg ADT Inc. Registration Statement on Form S-3 (File No. 333-235331)

Dear Mr. Anderegg:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-3 (the “S-3”) of ADT Inc. (the “Company”), Prime Security Services Holdings, LLC, Prime Security Services Borrower, LLC, Prime Finance Inc., The ADT Security Corp., ADT LLC and Red Hawk Fire & Security, LLC be accelerated to January 9, 2020 at 4:00 p.m. E.S.T. or as soon thereafter as may be practicable.

We understand that the Staff will consider this request as confirmation by the Company of its awareness of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Tracey A. Zaccone of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212) 373-3085.

*****

Very truly yours,
ADT Inc.

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 ADT INC.

1501 Yamato Road

 Boca Raton,
Florida 33431

 January 7, 2020

 VIA
EDGAR

 Division of Corporation Finance

 Securities and
Exchange Commission

 100 F Street, N.E.

 Washington, D.C.
20549

 Attention: Mr. Scott Anderegg

ADT Inc.

 Registration Statement
on

 Form S-3 (File No. 333-235331)

Dear Mr. Anderegg:

 Pursuant to Rule 461 of
the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-3 (the “S-3”) of ADT
Inc. (the “Company”), Prime Security Services Holdings, LLC, Prime Security Services Borrower, LLC, Prime Finance Inc., The ADT Security Corp., ADT LLC and Red Hawk Fire & Security, LLC be accelerated to January 9, 2020 at
4:00 p.m. E.S.T. or as soon thereafter as may be practicable.

 We understand that the Staff will consider this request as confirmation by
the Company of its awareness of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Tracey
A. Zaccone of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212) 373-3085.

 *****

Very truly yours,

ADT Inc.

Prime Security Services Holdings, LLC

Prime Security Services Borrower, LLC

By:

 /s/ Jeffrey Likosar

Name: Jeffrey Likosar

Title: Executive Vice President, Chief Financial Officer and Treasurer

Prime Finance Inc.

The ADT Security Corp.

ADT LLC

Red Hawk Fire & Security, LLC

By:

 /s/ Jeffrey Likosar

Name: Jeffrey Likosar

Title: Executive Vice President and Chief Financial Officer