0001104659-14-083547.txt : 20141229 0001104659-14-083547.hdr.sgml : 20141225 20141126110500 ACCESSION NUMBER: 0001104659-14-083547 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20141126 FILER: COMPANY DATA: COMPANY CONFORMED NAME: KLX Inc. CENTRAL INDEX KEY: 0001617898 STANDARD INDUSTRIAL CLASSIFICATION: AIRCRAFT & PARTS [3720] IRS NUMBER: 471639172 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1300 CORPORATE CENTER WAY, SUITE 200 CITY: WELLINGTON STATE: FL ZIP: 33414-2105 BUSINESS PHONE: 561-383-5100 MAIL ADDRESS: STREET 1: 1300 CORPORATE CENTER WAY, SUITE 200 CITY: WELLINGTON STATE: FL ZIP: 33414-2105 CORRESP 1 filename1.htm

 

November 26, 2014

 

VIA EDGAR

 

Justin Dobbie
Legal Branch Chief
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549

 

Re:

 

KLX Inc.

 

 

Registration Statement on Form 10-12B

 

 

File No. 001-36610

 

Dear Mr. Dobbie:

 

Reference is made to the Registration Statement on Form 10-12B (as amended to date, the “Registration Statement”) filed by KLX Inc. (the “Company”) with the United States Securities and Exchange Commission (the “Commission”).

 

In accordance with Rule 12d1-2 promulgated under the Securities Exchange Act of 1934, as amended, the Company hereby respectfully requests that the effective date of the Registration Statement be accelerated to November 26, 2014.

 

In addition, the Company hereby acknowledges that:

 

·                  should the Commission or the staff of the Commission (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;

 

·                  the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; 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.

 


 

If you should have any questions or further comments with respect to the Registration Statement, please direct them to Jason R. Lehner of Shearman & Sterling LLP at (212) 848-7974.  The Company requests that notification of the effectiveness of the Registration Statement be made by a telephone call to Mr. Lehner and that such effectiveness also be confirmed in writing.

 

 

 

Sincerely,

 

 

 

/s/ Thomas P. McCaffrey

 

 

 

Thomas P. McCaffrey

 

President and Chief Operating Officer

 

cc:

 

Jason R. Lehner, Esq.

 

 

Shearman & Sterling LLP