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| NEW YORK |
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| 601 Lexington Avenue |
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| 31st Floor |
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| New York, NY 10022 |
| T | + 1 212 284 4926 |
| F | + 1 646 521 5726 |
| W | www.freshfields.com |
| DOC ID | US3000834 |
| OUR REF | VFJ |
| CLIENT-MATTER NO | 164661-0019 |
June 1, 2018
VIA EDGAR AND HAND DELIVERY
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re: |
| KLX Inc. |
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| Preliminary Proxy Statement on Schedule 14A |
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| Filed on June 1, 2018 |
Ladies and Gentlemen:
On behalf of our client, KLX Inc. (the Company), we hereby file with the Securities and Exchange Commission the Company’s preliminary proxy statement on Schedule 14A with respect to the merger agreement pursuant to which the Company will be acquired by The Boeing Company.
If you have any questions or comments concerning this submission or require any additional information, please do not hesitate to contact the undersigned at (212) 284 4926 or Valerie.Jacob@freshfields.com.
| Sincerely, |
|
|
| /s/ Valerie Ford Jacob |
| Valerie Ford Jacob |
cc: Roger Franks, General Counsel, Vice President—Law and Human Resources
The Freshfields Bruckhaus Deringer US LLP partners include members of the Bars of the State of New York and the District of Columbia, Solicitors of the Supreme Court of England and Wales and Rechtsanwälte of Germany