October 11, 2007
CONFIDENTIAL
Jeffrey P. Riedler, Esq.
Assistant Director
Office of Healthcare and Insurance
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 6010
100 F Street, N.E.
Washington, D.C. 20549
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| Re: | PRA International
Preliminary Transaction Statement onSchedule 13E-3
Filed August 28, 2007
FileNo. 5-80376 |
Dear Mr. Riedler:
Under the Securities Exchange Act of 1934, as amended, PRA International, GG Holdings I, Inc., GG Merger Sub I, Inc., Genstar Capital Partners V, L.P., Genstar Capital Partners IV, L.P., Genstar Capital Partners III, L.P., Jean-Pierre L. Conte and Robert J. Weltman have filed an amendment to the above-captioned Preliminary Transaction Statement.
The undersigned hereby acknowledge that: (1) the undersigned are responsible for the adequacy and the accuracy of the disclosure in the filing; (2) comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and (3) the undersigned 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.
Very truly yours,
GG Holdings I, Inc.
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| | By: | /s/ Robert J. Weltman |
| | |
| | Name: Robert J. Weltman
Title: | Vice President, Secretary and Treasurer |
GG Merger Sub I, Inc.
| | |
| | By: | /s/ Robert J. Weltman |
| | |
| | Name: Robert J. Weltman
Title: | Vice President, Secretary and Treasurer |
Genstar Capital Partners V, L.P.
By: Genstar Capital V, L.P.
Its: General Partner
By: Genstar V GP LLC
Its: General Partner
| | |
| | By: | /s/ Robert J. Weltman |
| | |
| | Name: Robert J. Weltmann
Title: | Managing Director |
Genstar Capital Partners IV, L.P.
By: Genstar Capital V, L.P.
Its: General Partner
By: Genstar IV GP LLC
Its: General Partner
| | |
| | By: | /s/ Robert J. Weltman |
| | |
| | Name: Robert J. Weltman
Title: | Managing Director |
Genstar Capital Partners III, L.P.
By: Genstar Capital V, L.P.
Its: General Partner
By: Genstar III GP LLC
Its: General Partner
| | |
| | By: | /s/ Jean-Pierre L. Conte |
| | |
| | Name: Jean-Pierre L. Conte
Title: | Managing Director |
Jean-Pierre L. Conte
Robert J. Weltman
