TENNANT COMPANY
701 North Lilac Drive
P.0. Box 1452
Minneapolis, MN 55440
January 17, 2018
VIA EDGAR
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549-6010
Attention: Pamela Long, Assistant Director
Re: Tennant Company
Request for Acceleration of
Registration Statement on Form S-4
File No. 333- 222468
Ladies and Gentlemen:
Pursuant to Rule 461 of Regulation C under the Securities Act of 1933, as amended, Tennant Company, a Minnesota corporation, hereby requests that the effective date of the above-captioned registration statement on Form S-4 be accelerated so that it will be declared effective at 4:00 P.M., Eastern Time on January 19, 2018, or as soon thereafter as may be practicable.
Tennant Company hereby authorizes Bryan Pitko and Stephen Quinlivan of Stinson Leonard Street LLP to orally modify or withdraw this request for acceleration. Please contact Mr. Pitko at (612) 335-7061 or Mr. Quinlivan at (612) 335-7076 with any questions you may have concerning this request, and please notify either of them when this request for acceleration has been granted.
Sincerely,
TENNANT COMPANY
By | /s/ Jeffrey L. Cotter |
|
| Jeffrey L. Cotter |
|
| Senior Vice President, General Counsel and Secretary |
|
