INSTALLED BUILDING PRODUCTS, INC.
495 South High Street, Suite 50
Columbus, Ohio 43215
February 10, 2014
VIA ELECTRONIC TRANSMISSION AND EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-1004
Re: | Installed Building Products, Inc. |
Registration Statement on Form S-1 (File No. 333-193247) |
Acceleration Request:
Requested Date: February 12, 2014
Requested Time: 3:00 PM Eastern Time
Ladies and Gentlemen:
Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, Installed Building Products, Inc. (the Company) hereby respectfully requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-193247) (the Registration Statement) so that it may become effective at the Requested Date and Requested Time set forth above, or as soon thereafter as practicable.
In connection with this acceleration request, the Company hereby acknowledges that:
(a) should the United States Securities and Exchange Commission (the Commission) or its staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
(b) the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the accuracy and adequacy of the disclosure in the Registration Statement; and
(c) it 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.
The Company understands that the staff will consider this request as confirmation by the Company of its awareness of its responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the Registration Statement.
[Signature page follows]
INSTALLED BUILDING PRODUCTS, INC. | ||
By: |
/s/ Michael T. Miller | |
Name: |
Michael T. Miller | |
Title: |
Executive Vice President and Chief Financial Officer |
[Signature Page Company Acceleration Request]
BY EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-3628
Attention: | Ms. Pamela A. Long |
Assistant Director |
February 10, 2014
Re: | Installed Building Products, Inc. |
Registration Statement Filed on Form S-1 |
Registration No. 333-193247 |
Ladies and Gentlemen:
In connection with the above-captioned Registration Statement, we wish to advise that between February 3, 2014 and the date hereof the number of Preliminary Prospectuses dated February 3, 2014, which were furnished to 6 prospective underwriters and distributed to underwriters, institutional investors, individuals, dealers, brokers and others was approximately 2,735.
We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 3:00 p.m., Eastern time, on February 12, 2014 or as soon thereafter as practicable.
[Signature Pages Follow]
Very truly yours,
DEUTSCHE BANK SECURITIES INC.
UBS SECURITIES LLC
As Representatives of the several Underwriters
BY: DEUTSCHE BANK SECURITIES INC.
By: | /s/ Warren F. Estey | |
Name: |
Warren F. Estey | |
Title: |
Managing Director |
By: | /s/ Benjamin Marsh | |
Name: |
Benjamin Marsh | |
Title: |
Director |
BY: UBS SECURITIES LLC
By: | /s/ Nathan Bond | |
Name: |
Nathan Bond | |
Title: |
Director |
By: | /s/ Justin Smolkin | |
Name: |
Justin Smolkin | |
Title: |
Executive Director |