Validus Holdings, Ltd.
29 Richmond Road
Pembroke, Bermuda HM 08
| September 26, 2011 |
VIA EDGAR AND EMAIL TRANSMISSION
David L. Orlic, Esq.
Special Counsel
Office of Mergers and Acquisitions
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-6010
RE: | Transatlantic Holdings, Inc. |
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| Preliminary Proxy Statement on Schedule 14A |
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| Filed on September 14, 2011 by Validus Holdings, Ltd., et al. |
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| File No. 001-10545 |
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Dear Mr. Orlic:
In response to the request of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated September 22, 2011 regarding the Preliminary Proxy Statement on Schedule 14A filed with the Commission on September 14, 2011, Validus Holdings, Ltd. (the “Company”) hereby acknowledges that:
(1) the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
(2) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and
(3) 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.
| VALIDUS HOLDINGS, LTD. | ||
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| By: | /s/ Joseph E. (Jeff) Consolino | |
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| Name: | Joseph E. (Jeff) Consolino |
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| Title: | President and Chief Financial Officer |
cc: | Robert F. Kuzloski, Esq. (Validus Holdings, Ltd.) |
| Stephen F. Arcano, Esq. (Skadden, Arps, Slate, Meagher & Flom LLP) |
| Todd E. Freed, Esq. (Skadden, Arps, Slate, Meagher & Flom LLP) |
| Jon A. Hlafter, Esq. (Skadden, Arps, Slate, Meagher & Flom LLP) |
