[LETTERHEAD OF QUIKSILVER, INC.]
October 8, 2013
VIA EDGAR
| Securities and Exchange Commission | ||||||
| Division of Corporate Finance | ||||||
| 100 F Street, N.E. | ||||||
| Washington, D.C. 20549-6010 | ||||||
| Attention: | Erin Wilson | |||||
| (202) 551-6047 | ||||||
| Re: | Quiksilver, Inc., QS Wholesale, Inc. | |||||
| and the Additional Registrants listed on Annex A hereto | ||||||
| Registration Statement on Form S-4 | ||||||
Ladies and Gentlemen:
Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, each of the undersigned registrants (each, a “Registrant”) hereby requests that the effectiveness of the registration statement on Form S-4, the file number of which is set forth opposite each such Registrant’s name onAnnex A hereto, filed on August 27, 2013 and amended on October 4, 2013, be accelerated by the Securities and Exchange Commission (the “Commission”) to 5:00 PM, Eastern time, on October 9, 2013, or as soon thereafter as practicable.
Each Registrant acknowledges that should 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. In addition, each Registrant acknowledges that the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve each Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing. Finally, each Registrant acknowledges that it may not assert the declaration of effectiveness of the filing as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
[Signature Pages Follow]
We request that we be notified of such effectiveness by a telephone call to Jeffrey Miller of Skadden, Arps, Slate, Meagher & Flom LLP at (213) 687-5222 and that such effectiveness also be confirmed in writing.
| Very truly yours, | ||||
| QUIKSILVER, INC. | ||||
| By: | /s/ Charles S. Exon | |||
| Name: | Charles S. Exon | |||
| Title: | Chief Administrative Officer, | |||
| General Counsel and Secretary | ||||
| QS WHOLESALE, INC. | ||||
| By: | /s/ Charles S. Exon | |||
| Name: | Charles S. Exon | |||
| Title: | President and Secretary | |||
| DC SHOES, INC. | ||||
| By: | /s/ Charles S. Exon | |||
| Name: | Charles S. Exon | |||
| Title: | President and Secretary | |||
| HAWK DESIGNS, INC. | ||||
| By: | /s/ Charles S. Exon | |||
| Name: | Charles S. Exon | |||
| Title: | President and Secretary | |||
| MERVIN MANUFACTURING, INC. | ||||
| By: | /s/ Charles S. Exon | |||
| Name: | Charles S. Exon | |||
| Title: | President and Secretary | |||
| QS RETAIL, INC. | ||||
| By: | /s/ Charles S. Exon | |||
| Name: | Charles S. Exon | |||
| Title: | President and Secretary | |||
| cc: | Quiksilver, Inc. | |
| Charles S. Exon | ||
| Richard Shields | ||
| Skadden, Arps, Slate, Meagher & Flom LLP | ||
| Jonathan Ko, Esq. | ||
Annex A
Registrant | Registration Statement on Form S-4 | |
| (File No.) | ||
| Quiksilver, Inc. | 333-190842 | |
| QS Wholesale, Inc. | 333-190842-05 | |
| DC Shoes, Inc. | 333-190842-04 | |
| Hawk Designs, Inc. | 333-190842-03 | |
| Mervin Manufacturing, Inc. | 333-190842-02 | |
| QS Retail, Inc. | 333-190842-01 | |
