June 24, 2016
VIA EDGAR AND OVERNIGHT DELIVERY
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Kathleen Suellentrop and James Lopez
Re: | Medpace Holdings, Inc. |
Registration Statement on Form S-1 |
CIK No. 0001668397 |
File No. 333- |
Ladies and Gentlemen:
On behalf of our client Medpace Holdings, Inc., a Delaware corporation (the Company), and pursuant to the applicable provisions of the Securities Act of 1933, as amended (the Securities Act), and the rules promulgated thereunder, please find enclosed for filing with the Securities and Exchange Commission (the Commission) a complete copy of the above-captioned Registration Statement on Form S-1 (as amended, the Registration Statement), which was initially submitted to the Commission on a confidential basis pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act on March 15, 2016 (the Draft Submission).
This amendment reflects certain revisions to Amendment No. 2 to the Draft Submission, which was confidentially submitted on May 25, 2016, in response to the comment letter from the staff of the Commission (the Staff) to Jesse J. Geiger, the Companys Chief Financial Officer, dated June 1, 2016. The response provided herein is based on information provided to Latham & Watkins LLP by the Company. For your convenience we are also providing five copies of the Registration Statement, marked to show changes against Amendment No. 2 to the Draft Submission, in the traditional non-EDGAR format.
The numbered paragraph in italics below sets forth the Staffs comment together with the Companys response. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Registration Statement.
June 24, 2016
Page 2
Business
Our Services, page 94
1. | We note your response to comment 2. Please revise pages 94-96 to (1) more clearly address your laboratory services, including the difference between laboratory only offerings and services performed as a component of a full service clinical development arrangement, and (2) indicate, consistent with your response, that laboratory only services are immaterial. |
Response: The Company respectfully acknowledges the Staffs comment and has revised its disclosure on page 96 of the Registration Statement accordingly.
June 24, 2016
Page 3
We hope that the foregoing has been responsive to the Staffs comment and look forward to resolving any outstanding issues as quickly as possible. Please do not hesitate to contact me at (212) 906-2918 with any questions or further comments you may have regarding this filing or if you wish to discuss the above.
Sincerely,
/s/ Gregory P. Rodgers
Gregory P. Rodgers
of LATHAM & WATKINS LLP
Enclosures
cc: (via e-mail)
Dr. August J. Troendle, Chief Executive Officer, Medpace Holdings, Inc.
Jesse J. Geiger, Chief Financial Officer, Medpace Holdings, Inc.
Stephen P. Ewald, Esq., General Counsel, Medpace Holdings, Inc.
Howard A. Sobel, Esq., Latham & Watkins LLP
Glenn R. Pollner, Esq., Gibson, Dunn & Crutcher LLP