0001493152-15-005292.txt : 20160115 0001493152-15-005292.hdr.sgml : 20160115 20151110172813 ACCESSION NUMBER: 0001493152-15-005292 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20151110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VIGILANT DIVERSIFIED HOLDINGS, INC./NV CENTRAL INDEX KEY: 0001653099 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-MANAGEMENT CONSULTING SERVICES [8742] IRS NUMBER: 474543540 STATE OF INCORPORATION: NV FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 433 N. CAMDEN DRIVE STREET 2: SUITE 600 CITY: BEVERLY HILLS STATE: CA ZIP: 90210 BUSINESS PHONE: 310-279-5169 MAIL ADDRESS: STREET 1: 433 N. CAMDEN DRIVE STREET 2: SUITE 600 CITY: BEVERLY HILLS STATE: CA ZIP: 90210 FORMER COMPANY: FORMER CONFORMED NAME: VIGILANT DIVERSIFIED HOLDINGS, INC. DATE OF NAME CHANGE: 20150915 CORRESP 1 filename1.htm

VIGILANT DIVERSIFIED HOLDINGS, INC.

433 N. Camden Drive, Suite 600, Beverly Hills, CA 90210

Office: 310-279-5169

Web Address: www.vigilantdiversifiedholdings.com

November 10, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, DC 20549

	Re:	Vigilant Diversified Holdings, Inc. Form S-1 Registration Statement
		Registration No. 333-206963

Acceleration Request

	Requested Date: November 12, 2015
	Requested Time: 2:30 PM Pacific Time

Ladies and Gentlemen:

Vigilant Diversified Holdings, Inc. (the “Registrant”), pursuant to Rule 461 under the Securities Act of 1933, as amended, hereby respectfully requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to declare the above-captioned Registration Statement on Form S-1 effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable.

The Registrant hereby authorizes Donald P. Hateley, an attorney with its outside legal counsel, Hateley & Hampton, to orally modify or withdraw this request for acceleration.

The Registrant hereby acknowledges that:

	●	should the Commission of the staff, acting pursuant to delegated authority, declare our filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

	●	the action of the Commission of the staff, acting pursuant to delegated authority, in declaring our filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

	●	the Registrant 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.

The Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Hateley at (310) 576-4758.

	Sincerely,

	VIGILANT DIVERSIFIED HOLDINGS, INC.

	/s/ Todd W. L. Vigil
	Todd W. L. Vigil
	Chairman & Chief Executive Officer