March 31, 2014
VIA EDGAR AND E-MAIL
Mr. Gabriel Eckstein
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Re: | IMS Health Holdings, Inc. (the “Company”) | |
| Registration Statement on Form S-1 | ||
| File No. 333-193159 |
Dear Mr. Eckstein:
In connection with the above-referenced Registration Statement, we wish to advise you that between March 24, 2014 and the date hereof we effected the distribution of approximately 13,890 copies of the Company’s Preliminary Prospectus dated March 24, 2014 to prospective underwriters, institutional investors, prospective dealers, brokers, individuals, rating agencies and others.
We will comply and have been informed by the other participating underwriters that they will comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
As Representatives of the several underwriters, we hereby join in the request of the Company that the effectiveness of the above-referenced Registration Statement, as amended, be accelerated to 4:00 p.m. EST on April 2, 2014, or as soon thereafter as practicable.
| Very truly yours, | ||
| J.P. MORGAN SECURITIES LLC, | ||
| GOLDMAN, SACHS & CO., | ||
| MORGAN STANLEY & CO. LLC, | ||
| As Representatives of the several Underwriters | ||
| J.P. MORGAN SECURITIES LLC | ||
| By: | /s/ Thomas V. Rueger, Jr. | |
| Name: | Thomas V. Rueger, Jr. | |
| Title: | Managing Director | |
| GOLDMAN, SACHS & CO. | ||
| By: | /s/ Matt Leavitt | |
| Name: | Matt Leavitt | |
| Title: | Managing Director | |
| MORGAN STANLEY & CO. LLC | ||
| By: | /s/ Jon Zimmerman | |
| Name: | Jon Zimmerman | |
| Title: | Vice President | |
[Signature Page to Request for Acceleration of Effectiveness]
