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– Release Delayed to: 12/13/13 ·As Of Filer Filing For·On·As Docs:Size Issuer Agent 11/08/13 Malibu Boats, Inc. DRS¶ 12/13/13 16:6.2M Donnelley … Solutions/FA |
Document/Exhibit Description Pages Size 1: DRS Draft Registration Statement by an Emerging Growth HTML 1.34M Company or a Foreign Private Issuer 16: COVER Comment-Response or Cover Letter to the SEC HTML 13K 2: EX-3 Articles of Incorporation/Organization or By-Laws HTML 32K 3: EX-3 Articles of Incorporation/Organization or By-Laws HTML 96K 4: EX-3 Articles of Incorporation/Organization or By-Laws HTML 8K 5: EX-10 Material Contract HTML 631K 6: EX-10 Material Contract HTML 60K 7: EX-10 Material Contract HTML 22K 8: EX-10 Material Contract HTML 76K 9: EX-10 Material Contract HTML 40K 10: EX-10 Material Contract HTML 37K 11: EX-10 Material Contract HTML 285K 12: EX-10 Material Contract HTML 25K 13: EX-10 Material Contract HTML 37K 14: EX-10 Material Contract HTML 17K 15: EX-10 Material Contract HTML 20K
SEC Cover letter |
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511 Union Street, Suite 2700 | 615.244.6380 main | ||
P.O. Box 198966 | 615.244.6804 fax | |||
Nashville, TN 37219-8966 | wallerlaw.com | |||
Waller Lansden Dortch & Davis, LLP 615.850.8586 direct |
CONFIDENTIAL SUBMISSION VIA EDGAR
Draft Registration Statement
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re: | Malibu Boats, Inc. |
Draft Registration Statement on Form S-1
Ladies and Gentlemen:
On behalf of our client, Malibu Boats, Inc. (the “Company”), we hereby confidentially submit a draft Registration Statement on Form S-1 (the “Registration Statement”) to the staff of the Securities and Exchange Commission for confidential nonpublic review pursuant to Section 6(e) of the Securities Act of 1933, as amended (the “Securities Act”). The Registration Statement submitted herewith relates to the initial public offering of the Company’s Class A Common Stock.
On behalf of our client, we confirm to you that as of the date of this letter, the Company is an “emerging growth company,” as defined in Section 2(a)(19) of the Securities Act, because its total gross revenues during the fiscal year ended June 30, 2013, its most recently completed fiscal year, were less than $1 billion. Please note this information is disclosed in the Company’s consolidated statements of income included in the Registration Statement on page F-4. In addition, on behalf of our client, we confirm to you that as of the date of this letter none of the disqualifying conditions set forth in Section 2(a)(19) of the Securities Act have occurred.
A formal filing of the Registration Statement will be made at a later date, which in no event will be later than 21 days before the Company commences its road show.
If you have any questions or comments concerning this confidential submission, please do not hesitate to contact the undersigned at (615) 850-8586 or david.wilson@wallerlaw.com, or Jack Springer, the Company’s Chief Executive Officer at (865) 458-5478 or jacks@malibuboats.com.
Regards,
/s/ David G. Wilson
Waller Lansden Dortch & Davis, LLP
Cc: Jack Springer, Malibu Boats, Inc.
This ‘DRS’ Filing | Date | Other Filings | ||
---|---|---|---|---|
Release Delayed to: | 12/13/13 | CORRESP, S-1 | ||
Filed on: | 11/8/13 | |||
11/4/13 | ||||
6/30/13 | ||||
List all Filings |
As Of Filer Filing For·On·As Docs:Size Issuer Filing Agent 12/06/13 SEC UPLOAD¶ 10/12/17 1:201K Malibu Boats, Inc. |