0001104659-14-082244.txt : 20141219 0001104659-14-082244.hdr.sgml : 20141219 20141120100426 ACCESSION NUMBER: 0001104659-14-082244 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20141120 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Neff Corp CENTRAL INDEX KEY: 0001617667 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-EQUIPMENT RENTAL & LEASING, NEC [7359] IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 3750 N.W. 87TH AVENUE STREET 2: SUITE 400 CITY: MIAMI STATE: FL ZIP: 33178 BUSINESS PHONE: (305) 513-3350 MAIL ADDRESS: STREET 1: 3750 N.W. 87TH AVENUE STREET 2: SUITE 400 CITY: MIAMI STATE: FL ZIP: 33178 CORRESP 1 filename1.htm

 

November 20, 2014

 

VIA EDGAR

 

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549-6010

Attn:                    Pamela Long

Leland Benton

Era Anagnosti

 

Re:                             Neff Corporation

Registration Statement on Form S-1

File No. 333-198559

 

Ladies and Gentlemen:

 

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned hereby join in the request of Neff Corporation that the effective date of the above-referenced Registration Statement be accelerated by the Securities and Exchange Commission (the “Commission”) so that the Registration Statement, as then amended, will become effective under the Securities Act at 2:00 p.m. ET on November 20, 2014 or as soon thereafter as practicable.

 

In connection with the Preliminary Prospectus distribution for the above-mentioned issue, the undersigned are, and the prospective underwriters have confirmed that they are, complying with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 

The following information with respect to the distribution of the Preliminary Prospectus dated November 10, 2014 is furnished pursuant to Rule 460 of the Rules and Regulations of the Commission under the Securities Act, in connection with the request for acceleration of the effective date of the Registration Statement.

 

The undersigned have effected approximately the following distribution of copies of the Preliminary Prospectus, dated November 10, 2014, through the date hereof:

 

Preliminary Prospectus, dated November 10, 2014:

 

5,470 copies were distributed to prospective underwriters, institutional investors, dealers and others.

 


 

Yours truly,

 

 

 

MORGAN STANLEY & CO. LLC

 

JEFFERIES LLC

 

 

 

As Representatives of the Several Underwriters

 

 

 

 

 

By:  Morgan Stanley & Co. LLC

 

 

 

 

 

By:

/s/ LAUREN GARCIA BELMONTE

 

 

Name:

Lauren Garcia Belmonte

 

 

Title:

Vice President

 

 

 

By:  Jefferies LLC

 

 

 

By:

/s/ ASHLEY DELP WALKER

 

 

Name:

Ashley Delp Walker

 

 

Title:

Managing Director

 

 

[Signature Page—Underwriters’ Acceleration Request]