IMS HEALTH INCORPORATED
901 Main Avenue
Norwalk, Connecticut 06851
December 17, 2009
Via EDGAR and Hand Delivery
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549-4561
Attention: Maryse Mills-Apenteng, Special Counsel
RE: | IMS Health Incorporated Preliminary Proxy Statement on Schedule 14A Filed November 25, 2009 File No. 001-14049 |
Dear Ms. Mills-Apenteng:
On December 11, 2009, Keith A. Pagnani from Sullivan & Cromwell LLP submitted a letter (the “Response Letter”), on behalf of IMS Health Incorporated (the “Company”), containing the responses of the Company to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter, dated December 2, 2009 (the “Comment Letter”), with respect to the above-referenced Preliminary Proxy Statement on Schedule 14A (the “Proxy Statement”).
In addition to the Response Letter and in response to the Comment Letter, the Company is filing this letter with the Commission electronically today and delivering via hand delivery a hard copy of this letter.
The Company hereby acknowledges that:
• | the Company is responsible for the adequacy and accuracy of the disclosure in the Proxy Statement; |
• | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Proxy Statement; and |
• | the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
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Sincerely, |
/s/ HARVEY A. ASHMAN |
Harvey A. Ashman Senior Vice President, General Counsel and External Affairs |
cc: | Barbara C. Jacobs Evan S. Jacobson (United States Securities and Exchange Commission) |
Keith A. Pagnani
Alan J. Sinsheimer
(Sullivan & Cromwell LLP)