0001193125-12-273630.txt : 20120720 0001193125-12-273630.hdr.sgml : 20120720 20120618144628 ACCESSION NUMBER: 0001193125-12-273630 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120618 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Justice Delaware Holdco Inc. CENTRAL INDEX KEY: 0001547282 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-EATING PLACES [5812] IRS NUMBER: 455011014 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 5505 BLUE LAGOON DRIVE CITY: MIAMI STATE: FL ZIP: 33133 BUSINESS PHONE: 305-378-3000 MAIL ADDRESS: STREET 1: 5505 BLUE LAGOON DRIVE CITY: MIAMI STATE: FL ZIP: 33133 FORMER COMPANY: FORMER CONFORMED NAME: Justice Delaware Holdco Inc. DATE OF NAME CHANGE: 20120412 CORRESP 1 filename1.htm Acceleration Request

Justice Delaware Holdco Inc.

1114 Avenue of the Americas, 41st Floor

New York, New York 10036

June 18, 2012

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

  Attention:    Justin Dobbie
     J. Nolan McWilliams

 

  Re: Justice Delaware Holdco Inc.
     Registration Statement on Form S-1
     File No. 333-181261

Ladies and Gentlemen:

Justice Delaware Holdco Inc. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-181261), as amended, to 9:00 a.m., Eastern Time, on Tuesday, June 19, 2012, or as soon thereafter as practicable.

In connection with the foregoing request for acceleration of effectiveness, the Company acknowledges that:

 

  •  

should the Securities and Exchange Commission (the “Commission”) or 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;

 

  •  

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 filing; and

 

  •  

the Company may not assert staff comments or 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 do not hesitate to contact Christopher A. Kitchen at (212) 446-4988 or Joshua N. Korff at (212) 446-4943 of Kirkland & Ellis LLP if there are any comments or questions concerning the foregoing.

 

Sincerely,
/s/ Martin E. Franklin
Martin E. Franklin
President