William Lyon Homes, Inc.
4695 MacArthur Court, 8th Floor
Newport Beach, CA 92660
July 23, 2018
VIA EDGAR
The Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Edward M. Kelly
| Re: | William Lyon Homes, Inc. and co-registrant guarantors |
Registration Statement on FormS-4
Filed July 3, 2018
FileNo. 333-226064
Dear Mr. Kelly:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned, William Lyon Homes, Inc. (the “Registrant”), hereby requests acceleration of the effective date of the Registration Statement referred to above so that it may become effective at 4:00 p.m. Eastern Standard Time on July 25, 2018, or as soon thereafter as practicable.
We acknowledge the following:
| • | should the U.S. Securities and Exchange Commission (the “Commission”) or its staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Registrant 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 appreciate your assistance in this matter.
| Very truly yours, | ||||
| WILLIAM LYON HOMES, INC., a California corporation | ||||
| By: | /s/ Jason R. Liljestrom | |||
| Name: | Jason R. Liljestrom | |||
| Title: | Senior Vice President, General Counsel & Corporate Secretary | |||
