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Form Type: CORRESP

Filing Date: 2025-03-06

Corporate Action: Ipo

Type: New

Accession Number: 000119312525048436

Filing Summary: Primo Brands Corporation requests the acceleration of the effective date of its Registration Statement on Form S-1, originally filed on January 24, 2025, with the SEC. The company seeks for the statement to become effective by 3:00 p.m. EST on March 7, 2025, or as soon as possible afterward. The request includes the desire for notification of effectiveness via phone to specific contacts at Latham & Watkins LLP.

Document Link: View Document

Additional details:

Registration Statement File No: 333-284501


Effective Date Request Time: 3:00 p.m. EST


Contact Name Primary: Jason Licht


Contact Name Secondary: Charles Cassidy


Contact Phone Primary: (202) 637-2258


Contact Phone Secondary: (202) 637-2176


Law Firm: Latham & Watkins LLP


Signatory Name: Marni Morgan Poe


Signatory Title: General Counsel & Corporate Secretary


Form Type: CORRESP

Filing Date: 2025-02-07

Corporate Action: Ipo

Type: Update

Accession Number: 000119312525022813

Filing Summary: Primo Brands Corp filed a letter on February 7, 2025, addressing comments from the Securities and Exchange Commission (SEC) regarding its registration statement on Form S-1. The Company provided updates in response to specific concerns raised by the SEC staff, including revisions to disclosures regarding industry reliance on spring water sources, cash flow expectations, credit ratings, and legal proceedings related to the Patane litigation. Enhanced explanations on material terms of water leases, revisions to risk factor language for consistency, and an acknowledgment of executive offer letter agreements were also included. The Company emphasized that it has more than 90 operational spring water sources to mitigate risks associated with individual source access. Amendments to the registration statement have been submitted alongside this response, and the Company aims to efficiently address all outstanding issues outlined by the SEC staff in their January 31, 2025, comment letter.

Document Link: View Document

Additional details:

Comment Letter Date: 2025-01-31


Registration Statement Date: 2025-01-24


Spring Sources Count: 90


Executive Offer Letters Date: 2024-12


Litigation Counsel: Jason M. Licht


Contact Number: (202) 637-2258


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