SEC Company Response from Adeia Inc. (ADEA) (CIK 0001803696) (ADEA) — Apr 20, 2020
Adeia Inc. (ADEA) (CIK 0001803696)
Date: April 20, 2020 · CIK: 0001803696 · Accession: 0001193125-20-112244
AI Filing Summary & Sentiment
File numbers found in text: 333-236492
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Re: XRAY-TWOLF HoldCo Corporation Registration Statement on Form S-4 Filed April 20, 2020 File No. 333-236492
Dear Ladies:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, XRAY-TWOLF HoldCo Corporation (the “Company”) hereby requests that the effectiveness under the Act of the above-captioned Registration Statement on Form S-4 (File No. 333-236492) (the “Registration Statement”) be accelerated to April 22, 2020 at 5:00 p.m. Eastern Time or as soon as thereafter practicable. By making this request for acceleration, the company confirms its obligations under the Securities Act of 1933. In connection with the acceleration request, the Company hereby acknowledges that:
•
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;
•
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
•
the Company 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.
U.S. Securities and Exchange Commission
Page
We request that we be notified of such effectiveness by a telephone call to Mike Ringler of Skadden, Arps, Slate, Meagher & Flom LLP at (650) 470-4620, and that such effectiveness also be confirmed in writing.
[Signature Page Follows]
Sincerely,
XRAY-TWOLF HoldCo Corporation
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CORRESP 1 filename1.htm CORRESP XRAY-TWOLF HoldCo Corporation 3025 Orchard Parkway San Jose, California 95134 April 20, 2020 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Ms. Melissa Gilmore Ms. Melissa Raminpour Ms. Sherry Haywood Ms. Erin Purnell Re: XRAY-TWOLF HoldCo Corporation Registration Statement on Form S-4 Filed April 20, 2020 File No. 333-236492 Dear Ladies: Pursuant to Rule 461 under the Securities Act of 1933, as amended, XRAY-TWOLF HoldCo Corporation (the “Company”) hereby requests that the effectiveness under the Act of the above-captioned Registration Statement on Form S-4 (File No. 333-236492) (the “Registration Statement”) be accelerated to April 22, 2020 at 5:00 p.m. Eastern Time or as soon as thereafter practicable. By making this request for acceleration, the company confirms its obligations under the Securities Act of 1933. In connection with the acceleration request, the Company hereby acknowledges that: • 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; • the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and • the Company 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. U.S. Securities and Exchange Commission Page 2 We request that we be notified of such effectiveness by a telephone call to Mike Ringler of Skadden, Arps, Slate, Meagher & Flom LLP at (650) 470-4620, and that such effectiveness also be confirmed in writing. [Signature Page Follows] 2 Sincerely, XRAY-TWOLF HoldCo Corporation /s/ Paul Davis Name: Paul Davis Title: Senior Vice President and General Counsel cc: Pamela Sergeeff, TiVo Corporation (via e-mail) Kenton J. King, Skadden, Arps, Slate, Meagher & Flom LLP (via e-mail) Mike Ringler, Skadden, Arps, Slate, Meagher & Flom LLP (via e-mail) Jon E. Gavenman, Cooley LLP (via e-mail) [Signature Page – Acceleration Request]