SEC Company Response from GFL Environmental Holdings Inc. (GFL) (CIK 0001780232) (GFL) — Feb 28, 2020
GFL Environmental Holdings Inc. (GFL) (CIK 0001780232)
Date: Feb. 28, 2020 · CIK: 0001780232 · Accession: 0001104659-20-026776
AI Filing Summary & Sentiment
Referenced dates: February 26, 2020
Letter
Simpson Thacher & Bartlett LLP
425 LEXINGTON AVENUE
NEW YORK, NY 10017-3954
TELEPHONE: (212) 455-2000
FACSIMILE: (212) 455-2502
Direct Dial Number
E-Mail Address
(212) 455-2293
rbekkerus@stblaw.com
February 28, 2020
VIA EDGAR TRANSMISSION
Re: GFL Environmental Holdings Inc.
Amendment No. 10 to Registration Statement on Form F-1
Filed on July 19, 2019
CIK No. 0001780232
Asia Timmons-Pierce
Jay Ingram
Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing and Construction
100 F Street, N.E.
Washington, D.C. 20549
Ladies and Gentlemen:
On behalf of GFL Environmental Holdings Inc. (the “Company”), we hereby file with the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) Amendment No. 10 (“Amendment No. 10”) to the above-referenced registration statement on Form F-1 (the “Registration Statement”). Unless otherwise defined below, terms defined in Amendment No. 10 and used below shall have the meanings given to them in Amendment No. 10. Page references in our response correspond to the pages of Amendment No. 10.
As previously indicated in the Company’s letter, dated February 27, 2020, in response to the Staff’s comment letter (the “Comment Letter”) dated February 26, 2020, in respect of comment 1 of such Comment Letter, the Company has revised the Registration Statement to update the Company’s disclosure, to include a new footnote (1) to the section titled “Summary—Summary Historical Consolidated Financial Information” on page 30 and to include additional information in footnote (2) to the Capitalization table on page 75.
* * * * * * * *
Please do not hesitate to call Ryan Bekkerus at (212) 455-2293 with any questions or further comments regarding this filing or if you wish to discuss any of the above responses.
Very truly yours,
/s/ Simpson Thacher & Bartlett LLP
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CORRESP 1 filename1.htm Simpson Thacher & Bartlett LLP 425 LEXINGTON AVENUE NEW YORK, NY 10017-3954 TELEPHONE: (212) 455-2000 FACSIMILE: (212) 455-2502 Direct Dial Number E-Mail Address (212) 455-2293 rbekkerus@stblaw.com February 28, 2020 VIA EDGAR TRANSMISSION Re: GFL Environmental Holdings Inc. Amendment No. 10 to Registration Statement on Form F-1 Filed on July 19, 2019 CIK No. 0001780232 Asia Timmons-Pierce Jay Ingram Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing and Construction 100 F Street, N.E. Washington, D.C. 20549 Ladies and Gentlemen: On behalf of GFL Environmental Holdings Inc. (the “Company”), we hereby file with the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) Amendment No. 10 (“Amendment No. 10”) to the above-referenced registration statement on Form F-1 (the “Registration Statement”). Unless otherwise defined below, terms defined in Amendment No. 10 and used below shall have the meanings given to them in Amendment No. 10. Page references in our response correspond to the pages of Amendment No. 10. As previously indicated in the Company’s letter, dated February 27, 2020, in response to the Staff’s comment letter (the “Comment Letter”) dated February 26, 2020, in respect of comment 1 of such Comment Letter, the Company has revised the Registration Statement to update the Company’s disclosure, to include a new footnote (1) to the section titled “Summary—Summary Historical Consolidated Financial Information” on page 30 and to include additional information in footnote (2) to the Capitalization table on page 75. * * * * * * * * Please do not hesitate to call Ryan Bekkerus at (212) 455-2293 with any questions or further comments regarding this filing or if you wish to discuss any of the above responses. Very truly yours, /s/ Simpson Thacher & Bartlett LLP Simpson Thacher & Bartlett LLP cc: Securities and Exchange Commission Nudrat Salik Al Pavot GFL Environmental Holdings Inc. Patrick Dovigi Stikeman Elliott LLP Jeffrey Singer Jeffrey Hershenfield Davis Polk & Wardwell LLP Deanna L. Kirkpatrick Shane Tintle Davies Ward Phillips & Vineberg LLP Shawn McReynolds Jennifer Grossklaus