November 25, 2015
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Justin Dobbie, Legal Branch Chief
Re: | Tribune Publishing Company |
| Registration Statement on Form S-3 |
| Filed November 16, 2015 |
| File No. 333-208023 |
Dear Mr. Dobbie:
In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, I am writing this letter on behalf of Tribune Publishing Company (the “Company”) to request that the Securities and Exchange Commission (the “Commission”) declare the above-captioned registration statement effective at 4:00 p.m., November 30, 2015, or as soon as practicable thereafter.
The Company acknowledges that:
· should 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 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.
November 25, 2015
Page 2
We request that we be notified of such effectiveness by a telephone call to Andrew B. Moore of Perkins Coie LLP, the Company’s counsel, at (206) 359-8649, or in his absence, Becky Marquez at (213) 237-7211, and that such effectiveness also be confirmed in writing.
| Sincerely, | |
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| /s/ Julie K. Xanders | |
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| Julie K. Xanders | |
| EVP, General Counsel | |
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cc: | Stewart Landefeld |
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| Andrew B. Moore |
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| Perkins Coie LLP |
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