Richard B. Aftanas, P.C. To Call Writer Directly: | 601 Lexington Avenue New York, New York | Facsimile: (212) 446-4900 |
July 21, 2017
VIA EDGAR AND FEDERAL EXPRESS
John Dana Brown
Attorney-Advisor
Office of Transportation and Leisure
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Re: | Swift Transportation Company | |
Amendment No. 1 to | ||
Registration Statement on Form S-4 | ||
Filed July 3, 2017 | ||
File No. 333-218196 |
Dear Mr. Brown:
Set forth below is the response of Swift Transportation Company (“Swift”) (“we”, “us” or “our”) to the comment received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”), by letter dated July 18, 2017, with respect to Swift’s Amendment No. 1 to Registration Statement on Form S-4 filed with the Commission on July 3, 2017, File No. 333-218196 (the “Registration Statement”). In connection with this letter responding to the Staff’s comment, we hereby submit to the Commission Amendment No. 2 to the Registration Statement (“Amendment No. 2”).
For the Staff’s convenience, our response is prefaced by the Staff’s corresponding comment in bold, italicized text. All references to page numbers and captions correspond to the page numbers and captions in Amendment No. 2.
Public Company Trading Multiples Analyses, page 89
1. | We note your response to our prior comment 21. Please revise to explain why the financial advisor chose only two “larger” companies for this analysis. |
Response:
In response to the Staff’s comment, we have revised the disclosure on page 89 of Amendment No. 2.
If you have any questions with respect to the foregoing, please do not hesitate to contact Richard B. Aftanas of Kirkland & Ellis LLP at (212) 446-4800 or via email at richard.aftanas@kirkland.com.
Sincerely, | |
/s/ Richard B. Aftanas | |
Richard B. Aftanas |
cc: | Via E-mail |
Richard Stocking (Swift Transportation Company) | |
Mickey R. Dragash (Swift Transportation Company) | |
Michael P. Brueck (Kirkland & Ellis LLP) | |
Claire E. James (Kirkland & Ellis LLP) | |
Todd F. Carlson (Knight Transportation, Inc.) | |
Philip Richter (Fried, Frank, Harris, Shriver & Jacobson LLP) | |
Maxwell Yim (Fried, Frank, Harris, Shriver & Jacobson LLP) | |
Mark A. Scudder (Scudder Law Firm, P.C., L.L.O.) | |
Earl H. Scudder (Scudder Law Firm, P.C., L.L.O.) | |
Patrick Kuhn (Securities and Exchange Commission) | |
Doug Jones (Securities and Exchange Commission) | |
Julie Griffith (Securities and Exchange Commission) |