BEMIS COMPANY, INC.
AMCOR FINANCE (USA), INC.
AMCOR PLC
AMCOR UK FINANCE PLC
AMCOR PTY LTD
C/o Amcor plc
83 Tower Road North, Warmley, Bristol BS30 8XP, United Kingdom
March 20, 2020
VIA EDGAR SUBMISSION
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Edward M. Kelly
Re: Registration Statement on Form S-1
Filed on March 9, 2020
File No. 333-237037
Request for Acceleration
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Bemis Company, Inc., Amcor Finance (USA), Inc., Amcor plc, Amcor UK Finance PLC and Amcor Pty Ltd (collectively, the “Registrants”), hereby request that the effective date of their Registration Statement on Form S-1 (File No. 333-237037) (the “Registration Statement”) be accelerated and that the Registration Statement be declared effective at 9:00 a.m., Washington, D.C. time, on March 23, 2020, or as soon thereafter as practicable. The Registrants hereby acknowledge that:
• should the Securities and Exchange Commission (the “Commission”) or the Commission’s staff (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
• the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
• the Registrants 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]
| Sincerely, | ||
| BEMIS COMPANY, INC. | ||
| By: | /s/ Daniel Sula | |
| Name: Daniel Sula | ||
| Title: Secretary and Director | ||
| AMCOR FINANCE (USA), INC. | ||
| AMCOR UK FINANCE PLC | ||
| By: | /s/ Graeme Vavasseur | |
| Name: Graeme Vavasseur | ||
| Title: Director | ||
| AMCOR PLC | ||
| By: | /s/ Michael Casamento | |
| Name: Michael Casamento | ||
| Title: Chief Financial Officer | ||
| AMCOR PTY LTD | ||
| By: | /s/ Anthony N. Avitabile | |
| Name: Anthony N. Avitabile | ||
| Title: Director | ||
[Signature Page to Form S-1 Acceleration Request Letter]