515 East Las Olas Boulevard, Suite 1200 | Fort Lauderdale, FL 33301 | T 954.525.100 | F 954.463.2030
Holland & Knight LLP | www.hklaw.com
Laurie Green
954 468 7808
laurie.green@hklaw.com
May 5, 2016
Via E-mail and EDGAR
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
Attention: Tom Kluck
Re: Interval Acquisition Corp. (the “Company”)
Registration Statement on Form S-4
Filed April 1, 2016
File No. 333-210533 (the “Registration Statement”)
Dear Mr. Kluck:
On behalf of the Company, we hereby respond to the Staff’s comment letter, dated April 11, 2016. The Company’s responses to the comments are set forth below.
General
1. �� We note your disclosure that the debt securities offered and sold pursuant to this prospectus are jointly and severally guaranteed by one or more guarantors. Rule 3-10 of Regulation S-X requires every guarantor of a registered security to file the financial statements required for a registrant unless an exception to the general rule applies. Please provide the condensed consolidating financial information required by Rule 3-10(f) of Regulation S-X or advise.
Response to Comment 1
Pursuant to Rule 3-10(d) of Regulation S-X, the Company has not presented separate financial statements for the subsidiary guarantors due to the presentation of condensed consolidating financial information set forth in Note 20 to the financial statements filed as exhibit 99.1 to the Form 8-K filed with the SEC by the Company’s parent, Interval Leisure Group, on May 5, 2016.