APX Group, Inc.
4931 North 300 West
Provo, Utah 84604
VIA EDGAR
September 6, 2017
| Re: | APX Group, Inc., APX Group Holdings, Inc. and other Guarantors |
| Registration Statement on FormS-4 (File No. 333-220269) |
Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549 |
Ladies and Gentlemen:
APX Group, Inc., a Delaware corporation (the “Issuer”), APX Group Holdings, Inc., a Delaware corporation (the “Parent Guarantor”) and certain subsidiaries of the Issuer listed in the above-referenced Registration Statement on FormS-4 (together with the Parent Guarantor, the “Guarantors” and together with the Issuer, the “Registrants”) pursuant to Rule 461 under the Securities Act of 1933, as amended, hereby request that the effective date of the above-referenced Registration Statement on FormS-4 be accelerated so that the Registration Statement may become effective at 2:00 p.m., Eastern Standard Time, on September 8, 2017, or as soon thereafter as practicable. We ask, however, that the Securities and Exchange Commission staff not accelerate such effectiveness until we or our representatives speak with you on that date.
We request that we be notified of such effectiveness by telephone call to Igor Fert at (212)455-2255 or Arjun Koshal at (212)455-3379 of Simpson Thacher & Bartlett LLP.
| Very truly yours, | ||
APX Group, Inc. and theCo-registrants | ||
| By: | /s/ Patrick Kelliher | |
| Name: | Patrick Kelliher | |
| Title: | Chief Accounting Officer | |