NCS Multistage Holdings, Inc.

19450 State Highway 249

Suite 200

Houston, TX 77070

April 25, 2017

VIA EDGAR AND EMAIL

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-3561

Attn: Loan Lauren P. Nguyen

 

Re:

NCS Multistage Holdings, Inc.

Registration Statement on Form S-1 (File No. 333-216580)

Ladies and Gentlemen:

We refer to the registration statement on Form S-1 (File No. 333-216580) (as amended, the “Registration Statement”), of NCS Multistage Holdings, Inc. (the “Company”), relating to the registration of the Company’s common stock, par value $0.01 per share.

In accordance with Rules 460 and 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby respectfully requests that the effectiveness of the Registration Statement be accelerated so that it may become effective at 4:00 P.M. (Eastern time) on Thursday, April 27, 2017, or as soon as practicable thereafter.

The Company hereby acknowledges the following:

 

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should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 

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the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 

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the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

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In addition, the Company hereby confirms that it is aware of its responsibilities under the Securities Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration Statement.

Please call Alexander D. Lynch at (212) 310-8971 or Aman Singh at (212) 310-8393, of Weil, Gotshal & Manges LLP, to confirm the effectiveness of the Registration Statement.