CORRESP

0001193125-18-162062.txt : 20180614 0001193125-18-162062.hdr.sgml : 20180614 20180514124002 ACCESSION NUMBER: 0001193125-18-162062 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20180514 FILER: COMPANY DATA: COMPANY CONFORMED NAME: HUNTINGTON INGALLS INDUSTRIES, INC. CENTRAL INDEX KEY: 0001501585 STANDARD INDUSTRIAL CLASSIFICATION: SHIP & BOAT BUILDING & REPAIRING [3730] IRS NUMBER: 900607005 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4101 WASHINGTON AVENUE STREET 2: 909-7, 7J2 CITY: NEWPORT NEWS STATE: VA ZIP: 23607 BUSINESS PHONE: (757) 380-2000 MAIL ADDRESS: STREET 1: 4101 WASHINGTON AVENUE STREET 2: 909-7, 7J2 CITY: NEWPORT NEWS STATE: VA ZIP: 23607 FORMER COMPANY: FORMER CONFORMED NAME: Huntington Ingalls Industries, Inc. DATE OF NAME CHANGE: 20101124 FORMER COMPANY: FORMER CONFORMED NAME: New Ships, Inc. DATE OF NAME CHANGE: 20101006 FORMER COMPANY: FORMER CONFORMED NAME: NEW S HOLDCO, INC. DATE OF NAME CHANGE: 20100917 CORRESP 1 filename1.htm CORRESP

Huntington Ingalls Industries, Inc.

4101 Washington Avenue

Newport News, VA 23607

May 14, 2018

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re:

Huntington Ingalls Industries, Inc.

Registration Statement on Form S-4

File No. 333-224676

Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Huntington Ingalls Industries, Inc. (the “Issuer”) and the additional registrants listed in the Registration Statement (together, with the Issuer, the “Registrants”) on Form S-4 (File No. 333-224676), as amended (the “Registration Statement”) hereby request acceleration of the effective date of their Registration Statement, so that it may become effective at 9:00 a.m., Washington, D.C. time, on May 16, 2018 or as soon thereafter as practicable.

The Registrants hereby acknowledge that:

(i)

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;

(ii)

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(iii)

the Registrants may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.


Very truly yours,

Huntington Ingalls Industries, Inc.

By:		/s/ Charles R. Monroe, Jr.
		Charles R. Monroe, Jr.
		Corporate Vice President, Associate General Counsel and Secretary

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