Nuveen Investments, Inc.
Windy City Investments, Inc.
Nuveen HydePark Group, LLC
Nuveen Asset Management
Nuveen Investments Advisers Inc.
Nuveen Investments Holdings, Inc.
Nuveen Investments Institutional Services Group LLC
NWQ Holdings, LLC
NWQ Investment Management Company, LLC
Nuveen Investment Solutions, Inc.
Rittenhouse Asset Management, Inc.
Santa Barbara Asset Management, LLC
Symphony Asset Management LLC
Tradewinds Global Investors, LLC
Winslow Capital Management, Inc.
333 West Wacker Drive
Chicago, Illinois 60606
November 5, 2009
VIA EDGAR AND FACSIMILE
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Re: |
| Registration Statement on Form S-4 (File No. 333-159221) of Nuveen Investments, Inc., Windy City Investments, Inc., Nuveen HydePark Group, LLC, Nuveen Asset Management, Nuveen Investments Advisers Inc., Nuveen Investments Holdings, Inc., Nuveen Investments Institutional Services Group LLC, NWQ Holdings, LLC, NWQ Investment Management Company, LLC, Nuveen Investment Solutions, Inc., Rittenhouse Asset Management, Inc., Santa Barbara Asset Management, LLC, Symphony Asset Management LLC, Tradewinds Global Investors, LLC and Winslow Capital Management, Inc. (the “Registrants”) |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the Registrants hereby respectfully request that the Securities and Exchange Commission (the “Commission”) take such action as may be necessary and proper in order that the above-referenced Registration Statement be declared effective at 10:00 a.m., eastern standard time, on Tuesday, November 10, 2009, or as soon thereafter as practicable.
In connection with this request, the Registrants acknowledge that:
1. Should the Commission or the staff thereof, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
2. The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and
3. 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.
Please call Matthew Costigan at (312) 558-6375 to provide notice of the effectiveness of the Registration Statement.
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| Respectfully submitted, |
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| /s/ John L. MacCarthy |
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| John L. MacCarthy |
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| Authorized Officer of each of the Registrants |
cc: Steven J. Gavin
Matthew Costigan
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