| McDara P. Folan, III Senior Vice President, Deputy General Counsel and Secretary
336-741-5162 336-728-4495 Fax folanm@rjrt.com |
November 17, 2015
VIA EDGAR CORRESPONDENCE AND EMAIL TO FIELDD@SEC.GOV
Mr. Donald E. Field
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Registration Statement on Form S-4 of Reynolds American Inc. and Additional |
Registrants (the “Registration Statement”)
SEC File Nos.: 333-207802 through 333-207802-12
Dear Mr. Field:
The undersigned registrants hereby request that the Securities and Exchange Commission accelerate the effective time and date of the above-referenced Registration Statement, and declare such Registration Statement effective as of 3:00 p.m., Washington, D.C. time, on Wednesday, November 18, 2015, or as soon thereafter as practical. The registrants also request that they be notified telephonically (by telephone call to the individuals listed at the end of this request letter) of the date and time of the effectiveness of the Registration Statement, and that the Commission subsequently transmit the written order of effectiveness to the registrants.
In connection with this request, the undersigned registrants hereby acknowledge that:
| • | should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and |
| • | the registrants may not assert 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. |
P.O. Box 2990 Winston-Salem, NC 27102 336.741.2000 www.reynoldsamerican.com Transforming Tobacco
Securities and Exchange Commission
November 17, 2015
Page 2
Please contact McDara P. Folan, III at (336) 741-5162, or David M. Eaton of the law firm of Kilpatrick Townsend & Stockton LLP at (404) 815-6051 with any questions or comments, or to notify the registrants telephonically of the effectiveness of the Registration Statement.
| Sincerely, | ||
AMERICAN SNUFF COMPANY, LLC CONWOOD HOLDINGS, INC. RAI SERVICES COMPANY REYNOLDS AMERICAN INC. R.J. REYNOLDS TOBACCO CO. R. J. REYNOLDS TOBACCO COMPANY R. J. REYNOLDS GLOBAL PRODUCTS, INC. R.J. REYNOLDS TOBACCO HOLDINGS, INC. ROSSWIL LLC SANTA FE NATURAL TOBACCO COMPANY, INC. | ||
| By: | /s/ McDara P. Folan, III | |
McDara P. Folan, III As an Authorized Officer for above-listed registrants | ||
LORILLARD LICENSING COMPANY LLC REYNOLDS INNOVATIONS INC. | ||
| By: | * | |
David A. Shirlen President | ||
| REYNOLDS FINANCE COMPANY | ||
| By: | * | |
Caroline M. Price President | ||
| *By: | /s/ McDara P. Folan, III | |
McDara P. Folan, III by powers-of-attorney included in signature pages to Registration Statement | ||