Correspondence 0001193125-24-178814 from Ardent Health, Inc. (ARDT)
Ardent Health, Inc.
Date: July 15, 2024 · CIK: 0001756655 · Accession: 0001193125-24-178814
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File numbers found in text: 333-280425
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CORRESP 1 filename1.htm CORRESP J.P. Morgan Securities LLC 383 Madison Avenue New York, New York 10179 BofA Securities, Inc. One Bryant Park New York, New York 10036 Morgan Stanley & Co. LLC 1585 Broadway New York, New York 10036 July 15, 2024 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services 100 F Street, N.E. Washington, D.C. 20549 Attention: Katherine Bagley Jeanne Baker Conlon Danberg Tracey Houser Re: Ardent Health Partners, LLC Registration Statement on Form S-1 Filed June 21, 2024, as amended File No. 333-280425 Acceleration Request Requested Date: July 17, 2024 Requested Time: 4:00 P.M. Eastern Time Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as the representatives of the several underwriters (the “Representatives”), hereby join in the request of Ardent Health Partners, LLC, a Delaware limited liability company (the “Company”), that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that it will be declared effective at 4:00 p.m. Eastern Time, on July 17, 2024, or as soon thereafter as practicable, or at such other time thereafter as the Company or its outside counsel, Sidley Austin LLP, may request by telephone to the staff of the Securities and Exchange Commission. Pursuant to Rule 460 under the Securities Act, we, as the Representatives, wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement. We, the undersigned Representatives, hereby represent that we are in compliance and will comply, and have been informed by the other participating underwriters that they are in compliance and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the offering pursuant to the above-referenced Registration Statement and Preliminary Prospectus. [Signature Page Follows] Very truly yours, J.P. Morgan Securities LLC BofA Securities, Inc. Morgan Stanley & Co. LLC, As Representatives of the several Underwriters J.P. MORGAN SECURITIES LLC By: /s/ Ben Burdett Name: Ben Burdett Title: Managing Director BOFA SECURITIES, INC. By: /s/ Jessica Lee-Hansen Name: Jessica Lee-Hansen Title: Managing Director MORGAN STANLEY & CO. LLC By: /s/ Chris Rigoli Name: Chris Rigoli Title: Executive Director [Signature Page to Underwriters’ Acceleration Request Letter]