Corp. Fin. No-Action Letter to Pentair, Inc. and Flow Control International Ltd. on Successor Issues

The OCC Division of Corporation Finance responded to a letter from Pentair, Inc. and Flow Control International Ltd.

The principal concern addressed in the letter was whether one issuer would be deemed a "successor" to another for purposes of, among other things, eligibility to use Form S-3, compliance with the current public information requirements of Rule 144(c)(1) under the Securities Act and filing new registration statements under the Securities Act for ongoing offerings of securities.

Cross-Reference(s): Exchange Act Rule 12g-3 and 12b-2; Securities Act Rule 144(c)(1) and 414.

View letter in full here (links externally to SEC website).
See also: Incoming Letter.