SEC Company Response from Cannae Holdings, Inc. (CNNE) (CIK 0001704720) (CNNE) — Oct 17, 2017
Cannae Holdings, Inc. (CNNE) (CIK 0001704720)
Date: Oct. 17, 2017 · CIK: 0001704720 · Accession: 0001104659-17-062560
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File numbers found in text: 333-217886
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CORRESP 1 filename1.htm Cannae Holdings, Inc. 1701 Village Center Circle Las Vegas, NV 89134 October 18, 2017 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549 Attn: Anne Nguyen Parker Re: Cannae Holdings, Inc. — Request for Acceleration Registration Statement on Form S-4 File No. 333-217886 Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Cannae Holdings, Inc. (the “Registrant”) hereby respectfully requests that the effectiveness of the above-captioned Registration Statement on Form S-4 (as amended to date, the “Registration Statement”) be accelerated to October 19, 2017 at 11 a.m. Eastern Time or as soon as practicable thereafter or at such later time as the Registrant or its counsel may orally request via telephone. The Registrant hereby acknowledges that: i. should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; ii. the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and iii. the Registrant 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. The cooperation of the staff in meeting the timetable described above is very much appreciated. If you have any questions, please feel free to contact Michael J. Aiello (michael.aiello@weil.com / telephone: 212.310.8552) or Sachin Kohli (sachin.kohli@weil.com / telephone: 212.310.8294) of Weil, Gotshal & Manges LLP. In addition, please notify Mr. Aiello or Mr. Kohli when this request for acceleration has been granted. Sincerely, Cannae Holdings, Inc. By: /s/ Michael L. Gravelle Name: Michael L. Gravelle Title: Executive Vice President, General Counsel and Corporate Secretary cc: Via E-mail Michael L. Gravelle, Esq. (Fidelity National Financial, Inc.) Michael J. Aiello, Esq. (Weil, Gotshal & Manges LLP) Sachin Kohli, Esq. (Weil, Gotshal & Manges LLP) 2