June 15, 2012
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
| Re: | MModal Inc. |
| Registration Statement on Form S-3 |
| File No. 333-180636 |
Ladies and Gentlemen:
MModal Inc. (the “Company”) hereby requests that, pursuant to Rule 461 under the Securities Act of 1933, as amended, the effective date of the Company’s registration statement on Form S-3, Registration No. 333-180636 (the “Registration Statement”) be accelerated so that the Registration Statement will become effective at 4:30 p.m., eastern time on June 18, 2012, or as soon thereafter as practicable.
The Company hereby acknowledges that:
| • | should the Securities and Exchange Commission (the “Commission”) or the 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; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company 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. |
| Sincerely, | ||
/s/ Kathryn F. Twiddy | ||
| Kathryn F. Twiddy | ||
| Chief Legal Officer | ||
