New Duke Holdco, Inc.

222 Berkeley Street, 5th Floor

Boston, Massachusetts 02116

 

December 8, 2021

 

VIA EDGAR

 

United States Securities and Exchange Commission
Division of Corporation Finance

Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549.

 

Attention: Stacey Peikin; Jennifer López-Molina

 

Re:

Acceleration Request for New Duke Holdco, Inc. Registration Statement on Form S-4 (File No. 333-260174)

 

To Whom It May Concern:

 

Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, New Duke Holdco, Inc. (the “Company”) hereby requests that the effective date of the Company’s Registration Statement on Form S-4, File Number 333-260174 (the “Registration Statement”) be accelerated so that it will become effective at 4:00 P.M., New York City time, on December 9, 2021, or as soon as practicable thereafter.

 

Please contact Scott D. Miller of Sullivan & Cromwell LLP via telephone on (212) 558-3109 or via e-mail (millersc@sullcrom.com), as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

 

[Signature page follows]

 

 

Securities and Exchange Commission December 8, 2021
	-2-

 

	Sincerely,
	New Duke Holdco, Inc.
	By	/s/ R. Stanton Dodge
		Name:	R. Stanton Dodge
		Title:	Secretary

 

cc:	Stacey Peikin
	Jennifer López-Molina
	(Securities and Exchange Commission)
	Scott D. Miller
	(Sullivan & Cromwell LLP)