J.P. MORGAN SECURITIES LLC 383 Madison Avenue New York, New York 10079 |
| MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED One Bryant Park New York, New York 10036 |
April 28, 2014
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549-3628
Attention: Suzanne Hayes
Re: Ares Management, L.P.
Registration Statement on Form S-1
File No. 333-194919
Acceleration Request
Ladies and Gentlemen:
As representatives of the several underwriters of the proposed public offering of 18,196,436 shares of common stock of Ares Management, L.P. (the “Company”), we hereby join the Company’s request to accelerate the date of the above-referenced Registration Statement, as then amended, effective as of 4:00 p.m. (New York time) on April 30, 2014, or as soon thereafter as is practicable.
Pursuant to Rule 460 under the Securities Act of 1933, as amended, we wish to advise you that we have distributed approximately 10,165 copies of the Company’s preliminary prospectus, dated April 22, 2014, through the date hereof, to underwriters, dealers, institutions and others.
The undersigned have been informed by the participating underwriters that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
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| Very truly yours, | |
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| J.P. MORGAN SECURITIES LLC | |
| MERRILL LYNCH, PIERCE, FENNER & SMITH | |
| INCORPORATED | |
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| As representatives of the several underwriters | |
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| By J.P. MORGAN SECURITIES LLC | |
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| By: | /s/ Hank Wilson |
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| Authorized Representative |
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| By MERRILL LYNCH, PIERCE, FENNER & SMITH | |
| INCORPORATED | |
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| By: | /s/ Michele A.H. Allong |
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| Authorized Representative |