ADT INC.
1501 Yamato Road
Boca Raton, Florida 33431
January 7, 2020
VIA EDGAR
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mr. Scott Anderegg
ADT Inc.
Registration Statement on
Form S-3 (FileNo. 333-235331)
Dear Mr. Anderegg:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on FormS-3 (the“S-3”) of ADT Inc. (the “Company”), Prime Security Services Holdings, LLC, Prime Security Services Borrower, LLC, Prime Finance Inc., The ADT Security Corp., ADT LLC and Red Hawk Fire & Security, LLC be accelerated to January 9, 2020 at 4:00 p.m. E.S.T. or as soon thereafter as may be practicable.
We understand that the Staff will consider this request as confirmation by the Company of its awareness of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Tracey A. Zaccone of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212)373-3085.
*****
| Very truly yours, | ||
| ADT Inc. | ||
| Prime Security Services Holdings, LLC | ||
| Prime Security Services Borrower, LLC | ||
| By: | /s/ Jeffrey Likosar | |
| Name: Jeffrey Likosar | ||
| Title: Executive Vice President, Chief Financial Officer and Treasurer | ||
| Prime Finance Inc. | ||
| The ADT Security Corp. | ||
| ADT LLC | ||
| Red Hawk Fire & Security, LLC | ||
| By: | /s/ Jeffrey Likosar | |
| Name: Jeffrey Likosar | ||
| Title: Executive Vice President and Chief Financial Officer | ||
