212-455-2579 | JMENDEZ@STBLAW.COM |
CONFIDENTIAL TREATMENT REQUESTED
March 25, 2013
Mr. Paul Dudek
Chief, Office of International Corporate Finance
Division of Corporate Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-7561
Re: | Graña y Montero S.A.A. |
Draft Registration Statement on Form F-1
Dear Mr. Dudek:
On behalf of our client, Graña y Montero S.A.A. (the “Company”), a Peruvian company, we are submitting herewith for confidential review and comment by the staff (the “Staff”) of the Securities and Exchange Commission the Company’s draft Registration Statement on Form F-1 (the “Draft Form F-1”) relating to a proposed offering in the United States of American depositary shares representing common shares of the Company.
On behalf of the Company, we hereby request that the Staff provide confidential treatment to the Draft Form F-1. This confidential treatment request is made under the Freedom of Information Act (“FOIA”) pursuant to Title 17 C.F.R. §200.83. It is our understanding that, pursuant to the FOIA regulations, (i) no determination as to the merits of our request for confidential treatment will be made at this time, and (ii) if the Staff receives a request for any of the information subject to this request for confidential treatment, we will be notified and provided with the opportunity to substantiate our request for confidential treatment.
MR. PAUL DUDEK | MARCH 25, 2013 | PG. 2 |
If you any have questions or require any additional information with respect to the above, please do not hesitate to reach me by telephone at 212-455-2579, by facsimile at 212-455-2502 or by email at jmendez@stblaw.com. In my absence, you may contact my colleague Cristina Quintero at 212-455-3473.
Very truly yours,
/s/ Juan Francisco Mendez
Juan Francisco Mendez
Enclosures
cc: | José Graña Miró Quesada |
Director
Graña y Montero S.A.A.
Mario Alvarado Pflucker
Chief Executive Officer and Director
Graña y Montero S.A.A.
Mónica Miloslavich Hart
Chief Financial Officer and Principal Accounting Officer
Graña y Montero S.A.A.
Claudia Drago Morante
Chief Legal Officer
Graña y Montero S.A.A.
Dennis Gray Febres
Corporate Finance and Investor Relations Officer
Graña y Montero S.A.A.