GENERAL ELECTRIC COMPANY
GE CAPITAL INTERNATIONAL HOLDINGS LIMITED
GE CAPITAL INTERNATIONAL FUNDING COMPANY UNLIMITED COMPANY
June 16, 2016
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-3628
Attn: Amanda Ravitz
Re: | General Electric Company/ GE Capital International Holdings Limited/ GE Capital International Funding Company Unlimited Company |
Registration Statement on Form S-4 (File No. 333-211798) |
Dear Ms. Ravitz:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, General Electric Company, GE Capital International Holdings Limited and GE Capital International Funding Company Unlimited Company, formerly GE Capital International Funding Company (collectively, the Registrants) hereby respectfully request that the effectiveness of the Registrants Registration Statement on Form S-4 (File No. 333-211798) filed on June 3, 2016 (the Registration Statement), be accelerated by the Securities and Exchange Commission (the Commission) so that it may become effective at 3:00 P.M., Eastern time, on Monday, June 20, 2016, or as soon as reasonably practicable thereafter.
The Registrants hereby acknowledge the following:
| should 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 Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| the Registrants 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 Registrants hereby confirm that they are aware of their 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.
Please call Corey R. Chivers of Weil, Gotshal & Manges LLP (212-310-8893) to confirm the effectiveness of the Registration Statement.
Very truly yours,
General Electric Company | ||
By: | /s/ Christoph A. Pereira | |
Name: | Christoph A. Pereira | |
Title: | Vice President, Chief Corporate, Securities and Finance Counsel | |
GE Capital International Holdings Limited | ||
By: | /s/ Sian Ong | |
Name: | Sian Ong | |
Title: | Authorized Signatory | |
GE Capital International Funding Company Unlimited Company | ||
By: | /s/ Robert Green | |
Name: | Robert Green | |
Title: | Director |
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cc: | Corey R. Chivers |
Partner |
Weil, Gotshal & Manges LLP |
Brian T. Sandstrom |
Executive Counsel, Corporate, Securities & Finance |
General Electric Company |
Brandon Smith |
Executive Counsel, Corporate, Securities & Finance |
General Electric Company |
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