DJO Finance LLC
DJO Finance Corporation
1430 Decision Street
Vista, California 92081
VIA EDGAR
August 29, 2016
| Re: | DJO Finance LLC |
| DJO Finance Corporation |
| and Subsidiary Guarantors |
| Registration Statement on Form S-4 (File No. 333-213164) |
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Dear Ladies and Gentlemen:
DJO Finance LLC, DJO Finance Corporation and each of the co-registrant subsidiary guarantors listed in the above-referenced Registration Statement on Form S-4 (together, the “Registrants”), pursuant to Rule 461 under the Securities Act of 1933, as amended, hereby requests that the effective date of the above-referenced Registration Statement on Form S-4 be accelerated so that the Registration Statement may become effective at 4:00 p.m., Eastern Standard Time, on August 31, 2016, or as soon thereafter as practicable.
The Registrants hereby acknowledge that:
| • | should the Securities and Exchange Commission (the “Commission”) or its staff, acting pursuant to delegated authority, declare the above-referenced 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 its 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 staff comments and 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. |
We request that we be notified of such effectiveness by telephone call to Richard Fenyes at (212) 455-2812, or in his absence, Diego Matamoros at (212) 455-2065, of Simpson Thacher & Bartlett LLP.
| Very truly yours, | ||||
| DJO Finance LLC | ||||
| DJO Finance Corporation | ||||
| DJO, LLC | ||||
| DJO Consumer, LLC | ||||
| Elastic Therapy, LLC | ||||
| Empi, Inc. | ||||
| Encore Medical Partners, LLC | ||||
| Encore Medical GP, LLC | ||||
| Encore Medical, L.P. | ||||
| By: | Encore Medical GP, LLC, its general partner | |||
| Rikco International, LLC | ||||
| By: | /s/ Joseph G. Martinez | |||
| Name: | Joseph G. Martinez | |||
| Title: | Senior Vice President and Assistant Secretary | |||
2
