0001037016-15-000026.txt : 20150818 0001037016-15-000026.hdr.sgml : 20150818 20150717140146 ACCESSION NUMBER: 0001037016-15-000026 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20150717 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NII HOLDINGS INC CENTRAL INDEX KEY: 0001037016 STANDARD INDUSTRIAL CLASSIFICATION: RADIO TELEPHONE COMMUNICATIONS [4812] IRS NUMBER: 911671412 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1875 EXPLORER ST. STREET 2: SUITE 1000 CITY: RESTON STATE: VA ZIP: 20190 BUSINESS PHONE: 7033905100 MAIL ADDRESS: STREET 1: 1875 EXPLORER ST. STREET 2: SUITE 1000 CITY: RESTON STATE: VA ZIP: 20190 FORMER COMPANY: FORMER CONFORMED NAME: NEXTEL INTERNATIONAL INC DATE OF NAME CHANGE: 19970919 FORMER COMPANY: FORMER CONFORMED NAME: MCCAW INTERNATIONAL LTD DATE OF NAME CHANGE: 19970402 CORRESP 1 filename1.htm Effectiveness Letter




NII Holdings, Inc.
1875 Explorer Street
Suite 800
Reston, VA 20190


July 17, 2015

BY EDGAR TRANSMISSION

Justin Kisner
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
    
Re:    NII Holdings, Inc.
Registration Statement on Form S-1
File No. 333-205665

Dear Mr. Kisner:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), NII Holdings, Inc. (the “Company”) hereby requests that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective under the Securities Act at 4:00 p.m. on Tuesday, July 21, 2015, or as soon thereafter as practicable.

The Company acknowledges that:

•
should the Securities and Exchange Commission (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 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.

Thank you for your assistance.

Very truly yours,

/s/ SHANA C. SMITH     
Shana C. Smith
Vice President, Deputy General Counsel and Secretary