STINSON LEONARD STREET LLP
50 South Sixth Street, Suite 2600
Minneapolis, MN 55402
January 8, 2018
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, D.C. 20549
Re:Tennant Company and Co-Registrants
Registration Statement on Form S-4
Ladies and Gentlemen:
This correspondence accompanies the above referenced registration statement. Please note that, as permitted by Securities Act Sections Compliance and Disclosure Interpretation No. 111.02, Tennant Company has included the applicable representations for an “Exxon Capital” exchange offer in the prospectus within the Summary of the Exchange Offer on pages 3 to 6, on page 18 under the caption “Purpose of the Exchange Offer,” on page 22 under the caption “Procedures for Tendering Restricted Notes” and on pages 26 to 27 under the caption “Consequences of Exchanging or Failing to Exchange Restricted Notes.”
Please contact the undersigned at (612) 335-7061 (email: bryan.pitko@stinson.com) or Steve Quinlivan at (612) 335-7076 (email: stephen.quinlivan@stinson.com) should you have any questions regarding this filing.
Very truly yours, |
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/s/ Bryan Pitko |
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Bryan Pitko |
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