Simpson Thacher & Bartlett LLP
900 G STREET, NW
WASHINGTON, D.C. 20001
TELEPHONE: +1-202-636-5500
FACSIMILE: +1-202-636-5502
| Direct Dial Number +1-202-636-5804 |
E-mail Address jbonnie@stblaw.com |
| VIA EDGAR | March 3, 2026 |
| Re: | Acceleration Request for Medline Inc. |
| Registration Statement on Form S-1 |
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Robert Augustin, Esq.
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, we attach the requests of our client, Medline Inc., and of the underwriters that effectiveness of the above-referenced Registration Statement be accelerated to 4:05 p.m., Washington, D.C. time, on March 4, 2026, or as soon as practicable thereafter.
Call me at (202) 636-5804 with any questions.
Very truly yours,
/s/ Joshua Ford Bonnie
Joshua Ford Bonnie
NEW YORK BEIJING BOSTON BRUSSELS HONG KONG HOUSTON LONDON LOS ANGELES LUXEMBOURG PALO ALTO SAN FRANCISCO SÃO PAULO TOKYO
March 3, 2026
VIA EDGAR
| Re: | Medline Inc. |
| Registration Statement on Form S-1 |
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E. Washington, D.C. 20549
Attention: Robert Augustin, Esq.
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Medline Inc. (the “Company”) hereby requests that the effective date of the above-referenced Registration Statement be accelerated so that it may become effective at 4:05 p.m., Washington, D.C. time, on March 4, 2026, or as soon as possible thereafter. In this regard, the Company is aware of its obligations under the Securities Act.
[Signature Page Follows]
| Very truly yours, | ||
| MEDLINE INC. | ||
| By: | /s/ Alexander M. Liberman | |
| Name: Alexander M. Liberman | ||
| Title: Chief Legal Officer | ||
Goldman Sachs & Co. LLC
200 West Street, New York, New York 10282
Morgan Stanley & Co. LLC
1585 Broadway, New York, New York 10036
BofA Securities, Inc.
One Bryant Park, New York, New York 10036
J.P. Morgan Securities LLC
270 Park Avenue, New York, New York 10017
March 3, 2026
VIA EDGAR
| Re: | Medline Inc. |
| Registration Statement on Form S-1 |
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Robert Augustin, Esq.
Ladies and Gentlemen:
In connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), and as representatives of the several underwriters of the proposed public offering of Medline Inc.’s (the “Company”) Class A common stock, we wish to advise you that we hereby join the Company’s request that the effective date of the above-referenced Registration Statement be accelerated so that it may become effective at 4:05 p.m., Washington, D.C. time, on March 4, 2026 or as soon as possible thereafter or at such later time as the Company or its counsel may request.
Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.
We, the undersigned, as representatives of the several underwriters, have complied and will continue to comply, and we have been informed by the participating underwriters that they have complied and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
[Signature Page Follows]
| Very truly yours,
GOLDMAN SACHS & CO. LLC MORGAN STANLEY & CO. LLC BOFA SECURITIES, INC. J.P. MORGAN SECURITIES LLC
As Representatives of the Underwriters | ||
| By: | GOLDMAN SACHS & CO. LLC | |
| By: | /s/ Lyla Bibi Maduri | |
| Name: Lyla Bibi Maduri | ||
| Title: Managing Director | ||
| By: | MORGAN STANLEY & CO. LLC | |
| By: | /s/ Kalli Dircks | |
| Name: Kalli Dircks | ||
| Title: Managing Director | ||
| By: | BOFA SECURITIES, INC. | |
| By: | /s/ Justin Walter | |
| Name: Justin Walter | ||
| Title: Managing Director | ||
| By: | J.P. MORGAN SECURITIES LLC | |
| By: | /s/ Benjamin Burdett | |
| Name: Benjamin Burdett | ||
| Title: Head of Healthcare ECM | ||