Parkway, Inc.
Bank of America Center
390 North Orange Avenue, Suite 2400
Orlando, Florida 32801
September 19, 2016
BY EDGAR AND FEDERAL EXPRESS
Mr. Tom Kluck
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | Parkway, Inc. |
| Registration Statement on Form 10 |
| File No. 001-37819 |
Dear Mr. Kluck:
Pursuant to Rule 12d1-2 under the Securities Exchange Act of 1934, as amended, Parkway, Inc. (the “Company”) hereby respectfully requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date and time of the above-referenced Registration Statement on Form 10, as amended (the “Registration Statement”), and declare the Registration Statement effective as of 4:00 p.m., Eastern time, on September 21, 2016, or as soon thereafter as practicable. The Company also requests that the Commission confirm such effective date and time in writing.
In connection with this request for acceleration, 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. |
Please contact Bruce W. Gilchrist of Hogan Lovells US LLP at (202) 637-5686 with any questions that you may have.
[Signature page follows]
Sincerely,
PARKWAY, INC. | ||
| /s/ A. Noni Holmes-Kidd | ||
| By: | A. Noni Holmes-Kidd | |
| Title: | Vice President and General Counsel | |
cc: Scott E. Francis
Parkway, Inc.
David W. Bonser
Matt N. Thomson
Hogan Lovells US LLP
Pamela F. Roper
Cousins Properties Incorporated
David E. Shapiro
Marshall P. Shaffer
Wachtell, Lipton, Rosen & Katz
