SEC Division of Corporation Finance no-action letter: Actavis, Inc.

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Section 15(d) and Rule 12h-3
Office of Chief Counsel
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attn: Kim McManus, Special Counsel
RE: Actavis, Inc. and Actavis plc
Ladies and Gentlemen:
We are writing on behalf of Actavis, Inc., a Nevada corporation (“Actavis”) to request that a letter be issued advising Actavis that the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) concurs with Actavis’s view that the updating of Actavis’s registration statement on Form S-3ASR (No. 333-184122) (the “Registration Statement”), pursuant to which the Actavis Debt (as defined herein) was issued, pursuant to Section 10(a)(3) of the Securities Act of 1933, as amended (the “Securities Act”), during the fiscal year ended December 31, 2013 would not preclude Actavis from utilizing Rule 12h-3 (“Rule 12h-3”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), to suspend its obligation to file with the Commission periodic and current reports required under Section 15(d) of the Exchange Act (“Section 15(d)”) and the rules and regulations promulgated thereunder, including its Annual Report on Form 10 -K for the fiscal year ended December 31, 2013 (the “2013 10-K”). 1