INFOR (US), INC.
641 Avenue of the Americas
New York, NY 10011
February 10, 2016
VIA FACSIMILE AND EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, D.C. 20549
FAX: (202) 772-9202
Attention: |
Mr. Gabriel Eckstein | |
Re: Infor (US), Inc. (the Company) Registration Statement on Form S-4 (SEC File No. 333-209105) Originally Filed January 25, 2016 |
Ladies and Gentlemen:
Pursuant to Rule 461 of the Securities Act of 1933, as amended (the Act), the Company and the Additional Registrants listed on Schedule A (collectively, the Registrants) to the Registration Statement on Form S-4, as amended (File No. 333-209105) (the Registration Statement), hereby request acceleration of the effective date of their Registration Statement to 4:00 p.m. Eastern Time, on February 12, 2016 or as soon thereafter as practicable.
The Registrants hereby acknowledge their responsibilities under the Act, as amended, and the Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the above-referenced Registration Statement. The Registrants hereby further acknowledge that:
| should the Securities and Exchange Commission (the Commission) or the staff, acting pursuant to delegated authority, declare this filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| the Registrants 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. |
Please call Joshua Korff, Michael Kim or Brian Hecht of Kirkland & Ellis LLP, counsel to the Company, at (212) 446-4943, (212) 446-4746 or (212) 446-4807, respectively, as soon as the Registration Statement has been declared effective or if you have any other questions or concerns regarding the matter.
Very truly yours, | ||
INFOR (US), INC. | ||
By: | /s/ Gregory M. Giangiordano | |
Name: | Gregory M. Giangiordano | |
Title: | President | |
INFOR, INC. | ||
INFINIUM SOFTWARE, INC. | ||
INFOR (GA), INC. | ||
SENECA ACQUISITION SUBSIDIARY INC. | ||
INFOR PUBLIC SECTOR, INC. | ||
By: | /s/ Gregory M. Giangiordano | |
Name: | Gregory M. Giangiordano | |
Title: | President |