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SEC Company Response from BrightView Holdings, Inc. (BV) (CIK 0001734713) (BV) — Jun 11, 2018

BrightView Holdings, Inc. (BV) (CIK 0001734713)
Date: June 11, 2018 · CIK: 0001734713 · Accession: 0001193125-18-188861

AI Filing Summary & Sentiment

File numbers found in text: 333-225277

Date
June 11, 2018
Author
/s/ Joseph H. Kaufman
Form
CORRESP
Company
BrightView Holdings, Inc. (BV) (CIK 0001734713)

Letter

SIMPSON THACHER & BARTLETT LLP

425 LEXINGTON AVENUE

NEW YORK, N.Y. 10017-3954

(212) 455-2000

______

FACSIMILE (212) 455-2502

DIRECT DIAL NUMBER

(212) 455-2948

E-MAIL ADDRESS

JKAUFMAN@STBLAW.COM

June 11, 2018

VIA EDGAR

Re:

BrightView Holdings, Inc.

Amendment No. 1 to

Registration Statement on Form S-1

File No. 333-225277

Anne Nguyen Parker, Assistant Director

Securities and Exchange Commission

Division of Corporation Finance

Office of Transportation and Leisure

100 F Street, N.E.

Washington, D.C. 20549

Ladies and Gentlemen:

On behalf of BrightView Holdings, Inc. (the “Company”), we hereby file with the Securities and Exchange Commission Amendment No. 1 (“Amendment No. 1”) to the above-referenced registration statement on Form S-1 (the “Registration Statement”). Amendment No. 1 has been updated primarily to reflect the 2.33839-for-1 reverse stock split the Company effected on June 8, 2018, and the information dependent upon the reverse stock split, and to otherwise update its disclosure.

To assist the Staff’s review of Amendment No. 1, we will send blacklined copies of Amendment No. 1 against the Registration Statement, which was filed on May 30, 2018.

Please do not hesitate to call me at (212) 455-2948 with any questions or comments regarding this filing.

Very truly yours,
/s/ Joseph H. Kaufman

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 SIMPSON THACHER & BARTLETT LLP

 425 LEXINGTON AVENUE

NEW YORK, N.Y. 10017-3954

(212) 455-2000

 ______

FACSIMILE (212) 455-2502

 DIRECT DIAL NUMBER

(212) 455-2948

 E-MAIL ADDRESS

JKAUFMAN@STBLAW.COM

 June 11, 2018

VIA EDGAR

 Re:

 BrightView Holdings, Inc.

 Amendment No. 1 to

 Registration Statement on Form S-1

 File No. 333-225277

Anne Nguyen Parker, Assistant Director

Securities and Exchange Commission

Division of Corporation Finance

Office of Transportation and Leisure

100 F Street, N.E.

 Washington,
D.C. 20549

 Ladies and Gentlemen:

On behalf of BrightView Holdings, Inc. (the “Company”), we hereby file with the Securities and Exchange Commission
Amendment No. 1 (“Amendment No. 1”) to the above-referenced registration statement on Form S-1 (the “Registration Statement”). Amendment No. 1 has been updated primarily to
reflect the 2.33839-for-1 reverse stock split the Company effected on June 8, 2018, and the information dependent upon the reverse stock split, and to otherwise
update its disclosure.

 To assist the Staff’s review of Amendment No. 1, we will send blacklined copies of
Amendment No. 1 against the Registration Statement, which was filed on May 30, 2018.

 Please do not hesitate to call
me at (212) 455-2948 with any questions or comments regarding this filing.

 Very truly yours,

/s/ Joseph H. Kaufman

Joseph H. Kaufman

 cc:

 Securities and Exchange Commission

 Effie Simpson

 Theresa Brillant

 Julia Griffith

 J. Nolan McWilliams

 BrightView Holdings, Inc.

 Andrew V. Masterman

 Jonathan M. Gottsegen

 Davis Polk & Wardwell LLP

 Byron B. Rooney

Joseph A. Hall