Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas
New York, New York 10019-6064
January 8, 2018
Via ELECTRONIC MAIL AND FEDERAL EXPRESS
CONFIDENTIAL
Ms. Pamela Long |
FOIA Confidential Treatment Request Under 17 C.F.R. §200.83
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Division of Corporation Finance Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 |
Re: | PlayAGS, Inc. Registration Statement onForm S-1 |
Ladies and Gentlemen:
On behalf of our client, PlayAGS, Inc., a Nevada corporation (the “Company”), we hereby provide the following preliminary proposed price range and share number information, which will be the basis for the information expected to be included in the Company’s preliminary prospectus (the “Preliminary Prospectus”) forming part of the Company’s Registration Statement on FormS-1 (the “Registration Statement”), filed with the Securities and Exchange Commission on December 19, 2017. Based on currently available information and market conditions, we expect the preliminary proposed price range to reflect an initial public offering price per share of the Company’s common stock, par value $0.01 per share (the “Shares”), of between $[****] and $[****] (the “Preliminary Price Range”), with an expected midpoint of the Preliminary Pricing Range of $[****], and [****] Shares offered to the public in connection with the offering (or [****] Shares if the underwriters’ over-allotment option to purchase additional shares is exercised in full), after giving effect to the[****]-for-one stock split of all of our outstanding shares of common stock, which will occur prior to the effectiveness of the Registration Statement in connection with the offering.
We also submit as Exhibit A hereto the accompanying changed pages to the Registration Statement, which we expect to include in the Preliminary Prospectus. The enclosed pages are marked to indicate changes from the Registration Statement and include, among other things, certain information previously left blank in the Registration Statement that is derived from the Preliminary Price Range, as well as changes to the financial statements derived from the Preliminary Price Range and changes to the section titled “Compensation Discussion and Analysis.”
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CONFIDENTIAL TREATMENT REQUESTED BY PLAYAGS, INC. |
The Company respectfully requests that certain of the information contained in this request letter be treated as confidential information and that the Commission provide timely notice to Victor Gallo, General Counsel, PlayAGS, Inc., 5475 S. Decatur Blv., Ste #100, Las Vegas, Nevada, 89118, telephone (702)722-6700, before it permits any disclosure of the underlined and highlighted information contained in this request letter.
Any questions or notifications with respect to this letter should be directed to the undersigned at (212)373-3055.
Sincerely, |
/s/ Monica K. Thurmond |
Monica K. Thurmond, Esq. |
cc: | Kimo Akiona |
PlayAGS, Inc.
Victor Gallo
PlayAGS, Inc.
Christodoulos Kaoutzanis, Esq.
Paul, Weiss, Rifkin, Wharton & Garrison LLP
CONFIDENTIAL TREATMENT REQUESTED
BY PLAYAGS, INC.
Exhibit A
[****]
CONFIDENTIAL TREATMENT REQUESTED
BY PLAYAGS, INC.