ORBITAL ATK, INC.
45101 Warp Drive
Dulles, VA 20166
June 8, 2015
VIA EDGAR AND ELECTRONIC MAIL
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Tonya K. Aldave
| Re: | Orbital ATK, Inc. |
| Registration Statement on Form S-4 (File No. 333-204660) |
| Request for Acceleration of Effective Date |
Dear Ms. Aldave:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Orbital ATK, 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 S-4 (the “Registration Statement”) and declare the Registration Statement effective as of 4:00 p.m., Eastern time, on June 10, 2015, or as soon thereafter as practicable. The Company also requests the Commission to 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 (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 responsibilities 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 to follow]
Very truly yours,
ORBITAL ATK, INC. | ||
| By: | /s/ Garrett E. Pierce | |
Garrett E. Pierce Chief Financial Officer | ||
| cc: | Eve N. Howard |
| John B. Beckman |
Signature Page toForm S-4 Registration Statement Request for Acceleration