Nielsen Finance LLC
Nielsen Finance Co.
and Guarantors
85 Broad Street
New York, NY 10004
VIA EDGAR
July 25, 2013
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Nielsen Finance Co.
and Guarantors
Registration Statement on Form S-4 (File No. 333-189456)
Dear Ladies and Gentlemen:
Nielsen Finance LLC, Nielsen Finance Co. and the co-registrant guarantors listed in the above-referenced Registration Statement on Form S-4 (together, the “Registrants”), pursuant to Rule 461 under the Securities Act of 1933, as amended, hereby request that the effective date of the above-referenced Registration Statement on Form S-4 be accelerated so that the Registration Statement may become effective at 3:00 p.m., Eastern Time, on July 26, 2013, or as soon thereafter as practicable.
The Registrants hereby acknowledge that:
| • | | should the Securities and Exchange Commission (the “Commission”) or its staff, acting pursuant to delegated authority, declare the above-referenced 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 its 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 |
| • | | 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. |
We request that we be notified of such effectiveness by telephone call to Joseph H. Kaufman of Simpson Thacher & Bartlett LLP at (212) 455-2948.
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Very truly yours, |
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Nielsen Finance LLC |
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By: | | * |
Name: | | David L. Calhoun |
Title: | | Chief Executive Officer |
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Nielsen Finance Co. |
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By: | | * |
Name: | | David L. Calhoun |
Title: | | Chief Executive Officer |
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A.C. Nielsen (Argentina) S.A. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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A.C. Nielsen Company, LLC |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President |
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ACN Holdings Inc. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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ACNielsen Corporation |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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ACNielsen eRatings.com |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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AGB Nielsen Media Research B.V. |
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By: | | * |
Name: | | Marcel Rutte |
Title: | | Managing Director |
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ART Holding, L.L.C. |
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By: A. C. Nielsen Company, LLC, its sole member |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President |
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Athenian Leasing Corporation |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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The Cambridge Group, Inc. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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CZT/ACN Trademarks, L.L.C. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President |
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G4 Analytics, Inc. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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Marketing Analytics, Inc. |
| |
By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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NetRatings, LLC |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President |
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Neurofocus, Inc. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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The Nielsen Company B.V. |
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By: | | * |
Name: | | David L. Calhoun |
Title: | | Chief Executive Officer and Director |
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The Nielsen Company (Luxembourg) S.à r.l. |
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By: | | * |
Name: | | Ruth Von Wyl |
Title: | | Manager A |
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By: | | * |
Name: | | Lisa Longo |
Title: | | Manager B |
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The Nielsen Company Finance (Ireland) Limited |
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By: | | * |
Name: | | Tim Farmer |
Title: | | Director |
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The Nielsen Company (US), LLC |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President |
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Nielsen Holding and Finance B.V. |
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By: | | * |
Name: | | Marcel Rutte |
Title: | | Managing Director |
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Nielsen Mobile, LLC |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President |
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Nielsen National Research Group, Inc. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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NMR Investing I, Inc. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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NMR Licensing Associates, L.P. |
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By: NMR Investing I, Inc., its general partner |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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The Perishables Group, Inc. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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TNC (US) Holdings, Inc. |
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By: | | * |
Name: | | David L. Calhoun |
Title: | | President and Chief Executive Officer |
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Vizu Corporation |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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VNU Intermediate Holding B.V. |
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By: | | * |
Name: | | Marcel Rutte |
Title: | | Managing Director |
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VNU International B.V. |
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By: | | * |
Name: | | Marcel Rutte |
Title: | | Managing Director |
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VNU Marketing Information, Inc. |
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By: | | * |
Name: | | James W. Cuminale |
Title: | | President and Director |
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* By: | | /s/ Harris Black |
Name: | | Harris Black |
Title: | | Attorney-in-fact |
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