0001104659-14-076466.txt : 20150115 0001104659-14-076466.hdr.sgml : 20150115 20141104153830 ACCESSION NUMBER: 0001104659-14-076466 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20141104 FILER: COMPANY DATA: COMPANY CONFORMED NAME: INC Research Holdings, Inc. CENTRAL INDEX KEY: 0001610950 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-COMMERCIAL PHYSICAL & BIOLOGICAL RESEARCH [8731] IRS NUMBER: 273403111 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 3201 BEECHLEAF COURT STREET 2: SUITE 600 CITY: RALEIGH STATE: NC ZIP: 27604 BUSINESS PHONE: 919-876-9300 MAIL ADDRESS: STREET 1: 3201 BEECHLEAF COURT STREET 2: SUITE 600 CITY: RALEIGH STATE: NC ZIP: 27604 CORRESP 1 filename1.htm

 

INC Research Holdings, Inc.

3201 Beechleaf Court, Suite 600

Raleigh, North Carolina 27604-1547

 

November 4, 2014

 

VIA EDGAR AND EMAIL

 

Securities and Exchange Commission

100 F Street, NE

Washington, D.C.  20549
Attn: Larry Spirgel

 

Re:                             INC Research Holdings, Inc.

Registration Statement on Form S-1

(File No. 333-199178)

 

Ladies and Gentlemen:

 

We refer to the registration statement on Form S-1 (File No. 333-199178) (as amended, the “Registration Statement”), of INC Research Holdings, Inc. (the “Company”), relating to the registration of the Company’s Class A Common Stock, par value $0.01 per share.

 

In accordance with Rule 461 under the Securities Act of 1933, as amended, the Company hereby respectfully requests the acceleration of the effectiveness of the Registration Statement so that it may become effective at 4:00 p.m. (Eastern time) November 6, 2014 or as soon as practicable thereafter.

 

The Company hereby acknowledges the following:

 

·                                          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 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.

 

In addition, the Company hereby confirms that it is aware of its responsibilities under the Securities Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration Statement.

 

Please call Heather L. Emmel of Weil, Gotshal & Manges LLP at (212) 310-8849 or Faiza N. Rahman at (212) 310-8235 to confirm the effectiveness of the Registration Statement.

 


 

 

Very truly yours,

 

 

 

INC Research Holdings, Inc.

 

 

 

By:

/s/ Christopher L. Gaenzle

 

 

Name: Christopher L. Gaenzle

 

 

Title: Chief Administrative Officer, General Counsel and Secretary

 

[Signature Page to Acceleration Request]