Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: | Dietrich A. King |
Assistant Director | |
Division of Corporation Finance |
August 15, 2017
Re: | IBM Credit LLC |
Registration Statement on Form S-3 | |
Filed August 4, 2017 | |
Registration No. 333-219724 |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, IBM Credit LLC (the “Company”) hereby respectfully requests acceleration of the effective date of the above-referenced Registration Statement to 2:00 p.m. Eastern time on August 17, 2017, or as soon as thereafter practicable.
It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform Stephen L. Burns at (212) 474-1146, and then send written confirmation to the addressees listed on the cover of the Registration Statement.
Very truly yours, | |||
IBM Credit LLC | |||
By: | /s/ Todd Hutchen | ||
Name: Todd Hutchen | |||
Title: Vice President, General Counsel and Secretary | |||