January 31, 2020
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
100 F Street, NE
Washington, DC 20549
Attention: Kevin Dougherty, Attorney-Advisor
Loan Lauren Nguyen, Legal Branch Chief
| Re: | ÐÇ¿Õ´«Ã½ Inc. |
| Registration Statement on Form S-4 |
| File No. 333-235855 |
Ladies and Gentlemen:
On behalf of ÐÇ¿Õ´«Ã½ Inc. (the “Company”), the undersigned hereby requests, pursuant to Rule 461(a) promulgated under the Securities Act of 1933, that the Registration Statement on Form S-4 (File No. 333-235855) of the Company be declared effective at 9:00 a.m. on February 4, 2020, or as soon thereafter as practicable. The Company respectfully requests that you notify Andrew C. Thomas of such effectiveness by a telephone call to (216) 586-1041.
[Signature Follows]