0001144204-17-061406.txt : 20180103 0001144204-17-061406.hdr.sgml : 20180103 20171129142858 ACCESSION NUMBER: 0001144204-17-061406 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20171129 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CISION LTD. CENTRAL INDEX KEY: 0001701040 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-PREPACKAGED SOFTWARE [7372] IRS NUMBER: 000000000 STATE OF INCORPORATION: E9 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 130 EAST RANDOLPH STREET, 7TH FLOOR CITY: CHICAGO STATE: IL ZIP: 60601 BUSINESS PHONE: (866) 639-5087 MAIL ADDRESS: STREET 1: 130 EAST RANDOLPH STREET, 7TH FLOOR CITY: CHICAGO STATE: IL ZIP: 60601 FORMER COMPANY: FORMER CONFORMED NAME: Capitol Acquisition Holding Co Ltd. DATE OF NAME CHANGE: 20170315 CORRESP 1 filename1.htm

Cision Ltd.

130 East Randolph Street, 7th Floor

Chicago, Illinois 60601

 

November 29, 2017

 

VIA EDGAR

 

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 

Attention:Jan Woo

Ivan Griswold

 

Re:Cision Ltd.

Registration Statement on Form S-1, as amended

Initial Filing Date November 29, 2017

File No. 333-221792

 

Ladies and Gentlemen:

 

Cision Ltd. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form S-1 (the “Registration Statement”), File No. 333-221792, as amended, to 9:00 a.m., Eastern Time, on Friday, December 1, 2017, or as soon thereafter as practicable.

 

The Company hereby acknowledges its responsibilities under the Securities Act of 1933, as amended, 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. In connection with the foregoing request for acceleration of effectiveness, the Company hereby further 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 contact Dennis M. Myers, P.C., of Kirkland & Ellis LLP, special counsel to the Company, at (312) 862-2232 as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

 

   
  Sincerely,
   
 

/s/ Jack Pearlstein

  Jack Pearlstein
  Chief Financial Officer