CONSTELLATION OIL SERVICES HOLDING S.A.
8-10, Avenue de la Gare
L-1610 Luxembourg
Grand Duchy of Luxembourg
RCS number: B163424
December 9, 2019
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Timothy S. Levenberg
| Re: | REQUEST FOR ACCELERATION OF EFFECTIVENESS Constellation Oil Services Holding S.A. Star International Drilling Limited |
Constellation Overseas Ltd. (in provisional liquidation)
Alpha Star Equities Ltd. (in provisional liquidation)
Gold Star Equities Ltd. (in provisional liquidation)
Hopelake Services Ltd.
Lone Star Offshore Ltd. (in provisional liquidation)
Snover International Inc. (in provisional liquidation)
Amaralina Star Holdco 1 Ltd
Brava Star Holdco 1 Ltd
Laguna Star Holdco 1 Ltd
Application for Qualification of Indenture on Form T-3
File No. 022-29078
Dear Mr. Timothy S. Levenberg:
We refer to the Application for Qualification of Indentures on Form T-3 with respect to the (i) 10.00% PIK / Cash Senior Secured Notes due 2024, comprised of 10.00% PIK / Cash Senior Secured First Lien Tranche due 2024, 10.00% PIK / Cash Senior Secured Second Lien Tranche due 2024 and 10.00% PIK / Cash Senior Secured Third Lien Tranche due 2024, (ii) 10.00% PIK / Cash Senior Secured Third Lien Notes due 2024, (iii) 10.00% PIK / Cash Senior Secured Fourth Lien Notes due 2024 and (iv) 6.25% PIK Senior Notes due 2030, originally filed with the Securities and Exchange Commission (the “Commission”) on August 9, 2019 (File No. 022-29078) (as amended by Amendment No. 1 filed with the Commission on December 9, 2019, the “Form T-3”), of Constellation Oil Services Holding S.A. (the “Issuer”) and Star International Drilling Limited, Constellation Overseas Ltd. (in provisional liquidation), Alpha Star Equities Ltd. (in provisional liquidation), Gold Star Equities Ltd. (in provisional liquidation), Hopelake Services Ltd., Lone Star Offshore Ltd. (in provisional liquidation), Snover International Inc. (in provisional liquidation), Amaralina Star Holdco 1 Ltd, Brava Star Holdco 1 Ltd, Laguna Star Holdco 1 Ltd (the “Guarantors”).
In accordance with Section 307(c) of the Trust Indenture Act of 1939, as amended, the Issuer and the Guarantors hereby respectfully request acceleration of the effective date of the above-referenced Form T-3 so that it may become effective at or prior to 9:00 a.m. Eastern Time, on Thursday, December 12, 2019, or as soon as possible thereafter.
Please contact Daniel Nam of White & Case LLP, U.S. counsel to the Company, at (212) 819-8542, 1221 Avenue of the Americas, New York, NY 10020, as soon as the Form T-3 has been declared effective, or if you have any other questions or comments regarding this matter.
[Remainder of Page Intentionally Blank]
Sincerely,
| CONSTELLATION OIL SERVICES HOLDING S.A. | ||
| By: | /s/ Camilo McAllister | |
| Name: | Camilo McAllister | |
| Title: | Chief Financial Officer | |
| By: | /s/ Fabíola Goulart | |
| Name | Fabíola Goulart | |
| Title: | Head of Finance | |
CONSTELLATION OVERSEAS LTD. (IN | ||
| PROVISIONAL LIQUIDATION) | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
LONE STAR OFFSHORE LTD. (IN PROVISIONAL | ||
| LIQUIDATION) | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
GOLD STAR EQUITIES LTD. (IN PROVISIONAL | ||
| LIQUIDATION) | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
SNOVER INTERNATIONAL INC. (IN PROVISIONAL | ||
LIQUIDATION) | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
Signature Page to SEC Acceleration Request
| STAR INTERNATIONAL DRILLING LIMITED | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
| ALPHA STAR EQUITIES LTD. (IN PROVISIONAL | ||
| LIQUIDATION) | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
HOPELAKE SERVICES LTD. | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
AMARALINA STAR HOLDCO 1 LTD | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
LAGUNA STAR HOLDCO 1 LTD | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
BRAVA STAR HOLDCO 1 LTD | ||
| By: | /s/ Michael Pearson | |
| Name: | Michael Pearson | |
| Title: | Director | |
Signature Page to SEC Acceleration Request
