Published on March 7, 2013
355 South Grand Avenue Los Angeles, California 90071-1560 Tel: +1.213.485.1234 Fax: +1.213.891.8763 www.lw.com |
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CONFIDENTIAL SUBMISSION VIA EDGAR |
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Milan | ||||
Draft Registration Statement |
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U.S. Securities and Exchange Commission |
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Division of Corporation Finance |
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100 F. Street, N.E. |
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Washington, D.C. 20549 |
Re: | Rexford Industrial, Inc. Draft Registration Statement on Form S-11 |
Ladies and Gentlemen:
On behalf of our client, Rexford Industrial, Inc. (the Company), we are submitting a draft Registration Statement on Form S-11 (the Registration Statement) to the staff of the Securities and Exchange Commission for confidential nonpublic review pursuant to Section 6(e) of the Securities Act of 1933, as amended (the Securities Act). The Registration Statement submitted herewith relates to the initial public offering of the Companys common stock.
On behalf of our client, we confirm to you that as of the date of this letter, the Company is an emerging growth company, as defined in Section 2(a)(19) of the Securities Act, because its total gross revenues during 2012, its most recently completed fiscal year, were less than $1.0 billion. In addition, on behalf of our client, we confirm to you that as of the date of this letter none of the disqualifying conditions set forth in Section 2(a)(19) have occurred.
A formal filing of the Registration Statement will be made at a later date, which in no event will be later than 21 days before the Company commences its road show.
March 7, 2013
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If you have any questions or comments concerning this submission, please do not hesitate
to call Bradley Helms at
(213) 891-8640 or Julian Kleindorfer at (213) 891-8371.
Very truly yours, |
/s/ Bradley Helms |
Bradley Helms |
of LATHAM & WATKINS LLP |