NEW PLUTO GLOBAL, INC.
1515 Broadway
New York, New York 10036
February 13, 2025
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Alexandra Barone, Esq.
| Re: | New Pluto Global, Inc. |
| Registration Statement on Form S-4 |
| File No. 333-282985 (the “Registration Statement”) |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, New Pluto Global, Inc. hereby requests that the effective date of the above-referenced Registration Statement be accelerated so that it may become effective at 12:00 p.m., Washington, D.C. time, on February 13, 2025, or as soon thereafter as practicable.
We request that we be notified of such effectiveness by telephone call to Hui Lin at (212) 455-7862 of Simpson Thacher & Bartlett LLP or Katharine L. Thompson at (202) 636-5860 of Simpson Thacher & Bartlett LLP.
| Very truly yours,
NEW PLUTO GLOBAL, INC. | ||||
| By: | /s/ Caryn Groce | |||
| Name: | Caryn Groce | |||
| Title: | Executive Vice President, Acting General Counsel and Secretary | |||
[Signature Page to Acceleration Request]
| cc: | Simpson Thacher & Bartlett LLP |
| Xiaohui (Hui) Lin |
| Katharine L. Thompson |