Neff Corporation
3750 N.W. 87th Avenue, Suite 400
Miami, FL 33178
November 20, 2014
VIA EDGAR TRANSMISSION
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
Attention: Pamela Long
Leland Benton
Era Anagnosti
Re: Neff Corporation
Registration Statement on Form S-1
File No. 333-198559
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-1, as amended (File No. 333-198559) (the “Registration Statement”) of Neff Corporation (the “Company”). We respectfully request that the Registration Statement become effective as of 2:00 p.m., Eastern Time, on November 20, 2014, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Kirk A. Davenport at (212) 906-1284.
The Company acknowledges the following:
· 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.
Thank you for your assistance in this matter.
| Very truly yours, | |
|
| |
| Neff Corporation | |
|
| |
| By: | |
|
| /s/ Mark Irion |
|
| Mark Irion |
|
|
|
|
| Chief Financial Officer |
cc: Graham Hood, Chief Executive Officer, Neff Corporation
Kirk A. Davenport, Esq., Latham & Watkins LLP
Dennis D. Lamont, Esq., Latham & Watkins LLP
