SIMPSON THACHER & BARTLETTLLP
425 LEXINGTON AVENUE
NEW YORK, N.Y. 10017-3954
(212) 455-2000
FACSIMILE (212) 455-2502
DIRECT DIAL NUMBER (212) 455-2202 | E-MAIL ADDRESS LPENG@STBLAW.COM |
| January 14, 2015 |
VIA EDGAR
| Re: | Patriot National, Inc. | |
| Registration Statement on Form S-1 | ||
| Registration No. 333-200972 |
Jeffrey P. Riedler
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington D.C. 20549
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, we attach the requests of our client, Patriot National, Inc., and of the underwriters that effectiveness of the above-referenced Registration Statement be accelerated to 2:00 p.m., Eastern Time, on January 15, 2015, or as soon as practicable thereafter.We ask, however, that the Securities and Exchange Commission staff not accelerate such effectiveness until we speak with you on that date.
Please do not hesitate to call me at (212) 455-2202 with any questions.
| Very truly yours, |
| /s/ Lesley Peng |
| Lesley Peng |
Patriot National, Inc.
401 E. Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
January 14, 2015
VIA EDGAR
| Re: | Patriot National, Inc. | |
| Registration Statement on Form S-1 | ||
| Registration No. 333-200972 |
Jeffrey P. Riedler
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington D.C. 20549
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. 333-200972) (the “Registration Statement”) of Patriot National, Inc. (the “Company”). We respectfully request that the Registration Statement become effective as of 2:00 p.m., Eastern Time, on January 15, 2015, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Simpson Thacher & Bartlett LLP, by calling Lesley Peng at (212) 455-2202.
The Company acknowledges the following:
| • | should the Securities and Exchange Commission (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. |
[Signature Page Follows]
Thank you for your assistance in this matter.
| Very truly yours, | ||||
| Patriot National, Inc. | ||||
| By: | /s/ Christopher A. Pesch | |||
| Name: | Christopher A. Pesch | |||
| Title: | Executive Vice President, General Counsel, Chief Legal Officer and Secretary | |||
January 14, 2015
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Patriot National, Inc. |
| Registration Statement on Form S-1 (File No. 333-200972) |
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as representatives of the several underwriters of Patriot National, Inc. (the “Company”) in connection with the proposed initial public offering of the Company’s common stock, we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 2:00 p.m., Eastern Time, on January 15, 2015, or as soon thereafter as is practicable.
Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, we wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated January 6, 2015, through the date hereof:
Preliminary Prospectus dated January 6, 2015:
3,037 copies to prospective underwriters, institutional investors, dealers and others.
The undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934.
Very truly yours,
UBS Securities LLC
As Representative of the several Underwriters
| UBS SECURITIES LLC | ||
| By: | /s/ Michael Jamin | |
| Name: Michael Jamin | ||
| Title: Managing Director | ||
| By: | /s/ Tushar Virmani | |
| Name: Tushar Virmani | ||
| Title: Director | ||