SWIFT TRANSPORTATION COMPANY
SWIFT SERVICES HOLDINGS, INC.
2200 South 75th Avenue
Phoenix, Arizona 85043
May 19, 2011
VIA FACSIMILE & EDGAR
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attn: Ms. Chanda DeLong Staff Attorney
Facsimile: (703) 813-6967
Re: Registration Statement on Form S-4 (File No. 333-173948-01)
Dear Ms. DeLong:
Pursuant to
Rule 461 of the Securities Act of 1933, as amended, Swift Services Holdings, Inc.,
a Delaware corporation (the Issuer), Swift Transportation Company, a Delaware corporation, and
the subsidiaries of Swift Transportation Company listed in the Registration Statement described
below (the Subsidiary Guarantors and, together with the Issuer and Swift Transportation Company,
the Registrants), respectfully request that the effective date of the Registration Statement on
Form S-4 (File No. 333-173948-01), filed by the Registrants on May 5, 2011 and amended on the date
hereof, be accelerated by the Securities and Exchange Commission (the
Commission) to May 19, 2011
at 3:00 p.m. Eastern Daylight Time or as soon as practicable thereafter.
The Registrants hereby acknowledge that:
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should the Commission or the staff of the Commission (the Staff), acting
pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing; |
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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 |
Ms. Chanda DeLong
Securities and Exchange Commission
May 19, 2011
Page 2
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the Registrants may not assert 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. |
The Registrants respectfully request that they be notified of such effectiveness by a
telephone call to Joshua Kaufman of Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-2609 and
that such effectiveness also be confirmed in writing.
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Very truly yours,
SWIFT TRANSPORTATION COMPANY
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By: |
/s/ James Fry
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Name: |
James Fry |
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Title: |
Executive Vice President, General
Counsel and Corporate Secretary |
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SWIFT SERVICES HOLDINGS, INC.
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By: |
/s/ James Fry
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Name: |
James Fry |
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Title: |
Secretary |
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cc: Joshua Kaufman, Skadden, Arps, Slate, Meagher & Flom LLP