0001193125-23-017366.txt : 20230301 0001193125-23-017366.hdr.sgml : 20230301 20230127143729 ACCESSION NUMBER: 0001193125-23-017366 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20230127 FILER: COMPANY DATA: COMPANY CONFORMED NAME: S&P Global Inc. CENTRAL INDEX KEY: 0000064040 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-CONSUMER CREDIT REPORTING, COLLECTION AGENCIES [7320] IRS NUMBER: 131026995 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 55 WATER STREET CITY: NEW YORK STATE: NY ZIP: 10041 BUSINESS PHONE: 212-438-1000 MAIL ADDRESS: STREET 1: 55 WATER STREET CITY: NEW YORK STATE: NY ZIP: 10041 FORMER COMPANY: FORMER CONFORMED NAME: MCGRAW HILL FINANCIAL INC DATE OF NAME CHANGE: 20130502 FORMER COMPANY: FORMER CONFORMED NAME: MCGRAW-HILL COMPANIES INC DATE OF NAME CHANGE: 19950502 FORMER COMPANY: FORMER CONFORMED NAME: MCGRAW HILL INC DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm CORRESP

S&P Global Inc.

55 Water Street

New York, New York 10041

January 27, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 

Re:  S&P Global Inc.

Registration Statement on Form S-4

File No. 333-269237

Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, S&P Global Inc. (the “Issuer”) and the additional registrant listed in the Registration Statement (together, with the Issuer, the “Registrants”) on Form S-4 (File No. 333-269237), as amended (the “Registration Statement”) hereby request acceleration of the effective date of their Registration Statement, so that it may become effective at 2 p.m., Washington, D.C. time, on January 31, 2023, or as soon thereafter as practicable.

The Registrants hereby acknowledge that:

 

  (i)

should the Securities and Exchange Commission (the “Commission”) or 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;

 

  (ii)

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

 

  (iii)

the Registrants may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 

 

Very truly yours,

S&P Global Inc.

By:

   /s/ Christopher F. Craig
 

Name: Christopher F. Craig

 

Title: Senior Vice President, Controller and Chief Accounting Officer