0001193125-21-117848.txt : 20210615 0001193125-21-117848.hdr.sgml : 20210615 20210415164341 ACCESSION NUMBER: 0001193125-21-117848 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210415 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell International L.L.C. CENTRAL INDEX KEY: 0001476297 IRS NUMBER: 742484917 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 800-823-9955 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell DFS Corp CENTRAL INDEX KEY: 0001855584 IRS NUMBER: 522049669 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Revolver Co L.P. CENTRAL INDEX KEY: 0001541822 IRS NUMBER: 203169301 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Technologies Inc. CENTRAL INDEX KEY: 0001571996 STANDARD INDUSTRIAL CLASSIFICATION: ELECTRONIC COMPUTERS [3571] IRS NUMBER: 800890963 STATE OF INCORPORATION: DE FISCAL YEAR END: 0128 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FORMER COMPANY: FORMER CONFORMED NAME: Dell Technologies Inc DATE OF NAME CHANGE: 20160825 FORMER COMPANY: FORMER CONFORMED NAME: Denali Holding Inc. DATE OF NAME CHANGE: 20130313 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Marketing Corp CENTRAL INDEX KEY: 0001658084 IRS NUMBER: 742485040 STATE OF INCORPORATION: DE FISCAL YEAR END: 0131 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY STREET 2: RR 1 MS 33 CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 512-728-7159 MAIL ADDRESS: STREET 1: ONE DELL WAY STREET 2: RR 1 MS 33 CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Marketing GP L.L.C. CENTRAL INDEX KEY: 0001658086 IRS NUMBER: 200218690 STATE OF INCORPORATION: DE FISCAL YEAR END: 0131 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY STREET 2: RR 1 MS 33 CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 512-728-7159 MAIL ADDRESS: STREET 1: ONE DELL WAY STREET 2: RR 1 MS 33 CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Marketing L.P. CENTRAL INDEX KEY: 0001658092 IRS NUMBER: 742616805 STATE OF INCORPORATION: TX FISCAL YEAR END: 0131 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY STREET 2: RR 1 MS 33 CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 512-728-7159 MAIL ADDRESS: STREET 1: ONE DELL WAY STREET 2: RR 1 MS 33 CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Denali Intermediate Inc. CENTRAL INDEX KEY: 0001658093 IRS NUMBER: 383897772 STATE OF INCORPORATION: DE FISCAL YEAR END: 0131 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY STREET 2: RR 1 MS 33 CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 512-728-7159 MAIL ADDRESS: STREET 1: ONE DELL WAY STREET 2: RR 1 MS 33 CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: EMC IP Holding Co LLC CENTRAL INDEX KEY: 0001855213 IRS NUMBER: 813742072 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DCC Executive Security Inc. CENTRAL INDEX KEY: 0001855228 IRS NUMBER: 752835372 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: (800) 289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Newfound Investment Partners LLC CENTRAL INDEX KEY: 0001855235 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 176 SOUTH STREET CITY: HOPKINTON STATE: MA ZIP: 01748 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NBT Investment Partners LLC CENTRAL INDEX KEY: 0001855236 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 176 SOUTH STREET CITY: HOPKINTON STATE: MA ZIP: 01748 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Flanders Road Holdings LLC CENTRAL INDEX KEY: 0001855240 IRS NUMBER: 043581091 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 176 SOUTH STREET CITY: HOPKINTON STATE: MA ZIP: 01748 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell World Trade L.P. CENTRAL INDEX KEY: 0001855276 IRS NUMBER: 742622003 STATE OF INCORPORATION: TX FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell USA L.P. CENTRAL INDEX KEY: 0001855278 IRS NUMBER: 742616802 STATE OF INCORPORATION: TX FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Products L.P. CENTRAL INDEX KEY: 0001855279 IRS NUMBER: 742616803 STATE OF INCORPORATION: TX FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Computer Holdings L.P. CENTRAL INDEX KEY: 0001855280 IRS NUMBER: 742674091 STATE OF INCORPORATION: TX FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Revolver Funding L.L.C. CENTRAL INDEX KEY: 0001855283 IRS NUMBER: 203598151 STATE OF INCORPORATION: NV FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: WILMINGTON TRUST SP SERVICES, INC STREET 2: 3993 HOWARD HUGHES PKWY., SUITE 250 CITY: LAS VEGAS STATE: NV ZIP: 01748 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell World Trade LP L.L.C. CENTRAL INDEX KEY: 0001855284 IRS NUMBER: 200219506 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell World Trade GP L.L.C. CENTRAL INDEX KEY: 0001855287 IRS NUMBER: 200219008 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell World Trade Corp CENTRAL INDEX KEY: 0001855289 IRS NUMBER: 200218917 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell USA LP L.L.C. CENTRAL INDEX KEY: 0001855291 IRS NUMBER: 200219119 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell USA GP L.L.C. CENTRAL INDEX KEY: 0001855292 IRS NUMBER: 200218658 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell USA Corp CENTRAL INDEX KEY: 0001855293 IRS NUMBER: 742485041 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ScaleIO LLC CENTRAL INDEX KEY: 0001855334 IRS NUMBER: 455051310 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 176 SOUTH STREET CITY: HOPKINTON STATE: MA ZIP: 01748 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell America Latina Corp. CENTRAL INDEX KEY: 0001855361 IRS NUMBER: 742924614 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: (800) 289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Colombia Inc. CENTRAL INDEX KEY: 0001855362 IRS NUMBER: 742850023 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: (800) 289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell DFS Group Holdings L.L.C. CENTRAL INDEX KEY: 0001855364 IRS NUMBER: 832277972 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Federal Systems Corp CENTRAL INDEX KEY: 0001855365 IRS NUMBER: 200218941 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Federal Systems GP L.L.C. CENTRAL INDEX KEY: 0001855366 IRS NUMBER: 200219046 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Federal Systems L.P. CENTRAL INDEX KEY: 0001855367 IRS NUMBER: 742924476 STATE OF INCORPORATION: TX FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Federal Systems LP L.L.C. CENTRAL INDEX KEY: 0001855368 IRS NUMBER: 200219487 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Financial Services L.L.C. CENTRAL INDEX KEY: 0001855369 IRS NUMBER: 742825828 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Global Holdings XV L.L.C. CENTRAL INDEX KEY: 0001855370 IRS NUMBER: 824674551 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Marketing LP L.L.C. CENTRAL INDEX KEY: 0001855371 IRS NUMBER: 200219147 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Product & Process Innovation Services Corp. CENTRAL INDEX KEY: 0001855372 IRS NUMBER: 204285143 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 701 E. PARMER LANE CITY: AUSTIN STATE: TX ZIP: 78753 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Products Corp CENTRAL INDEX KEY: 0001855373 IRS NUMBER: 742485611 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Products GP L.L.C. CENTRAL INDEX KEY: 0001855374 IRS NUMBER: 200218732 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Products LP L.L.C. CENTRAL INDEX KEY: 0001855375 IRS NUMBER: 200219283 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Revolver GP L.L.C. CENTRAL INDEX KEY: 0001855376 IRS NUMBER: 203286502 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Dell Technologies Capital, LLC CENTRAL INDEX KEY: 0001855377 IRS NUMBER: 850623964 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Wyse Technology L.L.C. CENTRAL INDEX KEY: 0001855386 IRS NUMBER: 942757606 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 5480 GREAT AMERICA PARKWAY CITY: SANTA CLARA STATE: CA ZIP: 01748 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: EMC Puerto Rico, Inc. CENTRAL INDEX KEY: 0001855472 IRS NUMBER: 660385528 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: GALERIA OFFICE TOWER STREET 2: B7 TABONUCO STREET, 11TH FL CITY: GUAYNABO STATE: PR ZIP: 00968 BUSINESS PHONE: 1-800-289-3355 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FILER: COMPANY DATA: COMPANY CONFORMED NAME: EMC CORP CENTRAL INDEX KEY: 0000790070 STANDARD INDUSTRIAL CLASSIFICATION: COMPUTER STORAGE DEVICES [3572] IRS NUMBER: 042680009 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 176 SOUTH STREET CITY: HOPKINTON STATE: MA ZIP: 01748-9103 BUSINESS PHONE: 5082937208 MAIL ADDRESS: STREET 1: 176 SOUTH STREET CITY: HOPKINTON STATE: MA ZIP: 01748-9103 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELL INC CENTRAL INDEX KEY: 0000826083 STANDARD INDUSTRIAL CLASSIFICATION: ELECTRONIC COMPUTERS [3571] IRS NUMBER: 742487834 STATE OF INCORPORATION: DE FISCAL YEAR END: 0129 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE DELL WAY STREET 2: STED CITY: ROUND ROCK STATE: TX ZIP: 78682-2244 BUSINESS PHONE: 5127284737 MAIL ADDRESS: STREET 1: ONE DELL WAY CITY: ROUND ROCK STATE: TX ZIP: 78682 FORMER COMPANY: FORMER CONFORMED NAME: DELL COMPUTER CORP DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm CORRESP

DELL INTERNATIONAL L.L.C.

EMC CORPORATION

One Dell Way

Round Rock, Texas 78682

April 15, 2021

VIA EDGAR

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 

  Re:

Dell International L.L.C., EMC Corporation and Guarantors Registration Statement on Form S-4

Ladies and Gentlemen:

In connection with the Registration Statement on Form S-4 of Dell International L.L.C., a Delaware limited liability company (“Dell International”), and EMC Corporation, a Massachusetts corporation (together with Dell International, the “Issuers”), and the additional registrants listed therein (collectively, the “Guarantors,” and together with the Issuers, the “Registrants”), we transmitted for filing by direct electronic transmission under the Securities Act of 1933, as amended (the “Securities Act”), a registration statement on Form S-4 (the “S-4 Registration Statement”), together with certain exhibits thereto, relating to the Issuers’ offers to exchange up to (i) $3,750,000,000 aggregate principal amount of their registered 5.450% First Lien Notes due 2023 (the “2023 Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered 5.450% First Lien Notes due 2023 that were issued on June 1, 2016 (the “2023 Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act, (ii) $1,000,000,000 aggregate principal amount of their registered 4.000% First Lien Notes due 2024 (the “2024 Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered 4.000% First Lien Notes due 2024 that were issued on March 20, 2019 (the “2024 Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act, (iii) $1,000,000,000 aggregate principal amount of their registered 5.850% First Lien Notes due 2025 (the “2025 Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered 5.850% First Lien Notes due 2025 that were issued on April 9, 2020 (the “2025 Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act, (iv) $4,500,000,000 aggregate principal amount of their registered 6.020% First Lien Notes due 2026 (the “June 2026 Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered 6.020% First Lien Notes due 2026 that were issued on June 1, 2016 (the “June 2026 Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act, (v) $1,750,000,000 aggregate principal amount of their registered 4.900% First Lien Notes due 2026 (the “October 2026 Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered 4.900% First Lien Notes due 2026 that were issued on March 20, 2019 (the “October 2026 Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act, (vi)

$500,000,000 aggregate principal amount of their registered 6.100% First Lien Notes due 2027 (the “2027 Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered 6.100% First Lien Notes due 2027 that were issued on April 9, 2020 (the “2027 Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act, (vii) $1,750,000,000 aggregate principal amount of their registered 5.300% First Lien Notes due 2029 (the “2029 Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered 5.300% First Lien Notes due 2029 that were issued on March 20, 2019 (the “2029 Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act, (viii) $750,000,000 aggregate principal amount of their registered 6.200% First Lien Notes due 2030 (the “2030 Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered First Lien Notes due 2030 that were issued on April 9, 2020 (the “2030 Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act, (ix) $1,500,000,000 aggregate principal amount of their registered 8.100% First Lien Notes due 2036 (the “2036 Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered 8.100% First Lien Notes due 2036 that were issued on June 1, 2016 (the “2036 Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act, and (x) $2,000,000,000 aggregate principal amount of their registered 8.350% First Lien Notes due 2046 (the “2046 Exchange Notes” and, together with the 2023 Exchange Notes, the 2024 Exchange Notes, the 2025 Exchange Notes, the June 2026 Exchange Notes, the October 2026 Exchange Notes, the 2027 Exchange Notes, the 2029 Exchange Notes, the 2030 Exchange Notes and the 2036 Exchange Notes, the “Exchange Notes”) for a like amount of the Issuers’ outstanding unregistered 8.350% First Lien Notes due 2046 that were issued on June 1, 2016 (the “2046 Outstanding Notes” and, together with the 2023 Outstanding Notes, the 2024 Outstanding Notes, the 2025 Outstanding Notes, the June 2026 Outstanding Notes, the October 2026 Outstanding Notes, the 2027 Outstanding Notes, the 2029 Outstanding Notes, the 2030 Outstanding Notes and the 2036 Outstanding Notes, the “Outstanding Notes”), which were offered and sold in reliance upon Rule 144A and Regulation S under the Securities Act. The Outstanding Notes are, and the Exchange Notes will be, fully and unconditionally guaranteed by the Guarantors, who are also Registrants under the S-4 Registration Statement.

The Registrants are registering the exchange offer on the S-4 Registration Statement in reliance on the position of the Securities and Exchange Commission (the “Commission”) enunciated in Exxon Capital Holdings Corp., available May 13, 1988 (“Exxon Capital”), Morgan Stanley & Co., Inc., available June 5, 1991 (regarding resales) and Shearman & Sterling, available July 2, 1993 (with respect to the participation of broker-dealers.) In connection with the S-4 Registration Statement, the Registrants hereby confirm and represent as follows:

1. The Registrants have not entered into any arrangement or understanding with any person to distribute the Exchange Notes and, to the best of each of the Registrants’ information and belief without independent investigation, each person participating in the exchange offer is acquiring the Exchange Notes in its ordinary course of business and is not engaged in, does not intend to engage in, and has no arrangement or understanding with any person to participate in, the distribution of the Exchange Notes. In this regard, the Registrants will disclose to each person participating in the exchange offer that if such person is participating in the exchange offer for the purpose of distributing the Exchange

 

-2-

Notes, such person (i) could not rely on the Staff’s position enunciated in Exxon Capital or interpretive letters to similar effect and (ii) must comply with registration and prospectus delivery requirements of the Securities Act in connection with a secondary resale transaction. Each Registrant acknowledges that such a secondary resale transaction by such person participating in the exchange offer for the purpose of distributing the Exchange Notes should be covered by an effective registration statement containing the selling security holder information required by Item 507 of Regulation S-K.

2. No broker-dealer has entered into any arrangement or understanding with the Registrants or an affiliate of the Registrants to distribute the Exchange Notes. The Registrants will disclose to each person participating in the exchange offer (through the exchange offer prospectus) that any broker-dealer who receives any Exchange Notes for its own account pursuant to the exchange offer may be a statutory underwriter and must deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of those Exchange Notes. The Registrants will also include in the letter of transmittal to be executed by each holder participating in the exchange offer that each broker-dealer that receives such Exchange Notes for its own account pursuant to the exchange offer must acknowledge that it will deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of those Exchange Notes and that by so acknowledging and delivering a prospectus, the broker-dealer will not be deemed to admit that it is an “underwriter” within the meaning of the Securities Act.

The filing fee for the S-4 Registration Statement in the amount of $2,018,350 has previously been deposited by wire transfer of same day funds to the Commission’s account at U.S. Bank.

If you have any questions on the above-referenced S-4 Registration Statement, please contact the undersigned at (800) 289-3355 or Hui Lin of Simpson Thacher & Bartlett LLP at (212) 455-7862.

****

 

-3-

Very truly yours,
DELL INTERNATIONAL L.L.C.
By:  

/s/ Robert L. Potts

Name:   Robert L. Potts
Title:   Senior Vice President and Assistant Secretary

 

EMC CORPORATION
By:  

/s/ Robert L. Potts

Name:   Robert L. Potts
Title:   Senior Vice President and Assistant Secretary

 

[Signature Page – Transmittal Letter to SEC]