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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

Date
July 15, 2024
Author
J.P. Morgan Securities LLC
Form
CORRESP
Company
Ardent Health, Inc.

Letter

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

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

Show Raw Text
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]