The GEO Group, Inc.
One Park Place, Suite 700
621 Northwest 53rd Street
Boca Raton, Florida 33487-8242
January 2, 2014
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Registration Statement on Form S-4 |
(SEC Registration No. 333-192170) (the Registration Statement) |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the Securities Act), The GEO Group, Inc. (the Company) requests that the effectiveness of the Registration Statement referenced above be accelerated at 9:30 a.m. on January 6, 2014, or as soon as possible thereafter.
As requested, the Company acknowledges that:
| should 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; |
| 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 |
| 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. |
Sincerely, |
The GEO Group, Inc. |
/s/ Brian R. Evans |
Brian R. Evans |
Senior Vice President and Chief Financial Officer |
GEO RE Holdings LLC |
Correctional Services Corporation, LLC |
CPT Limited Partner, LLC |
CPT Operating Partnership L.P. |
Correctional Properties Prison Finance LLC |
Public Properties Development and Leasing LLC |
GEO Holdings I, Inc. |
GEO Acquisition II, Inc. |
GEO Transport, Inc. |
Cornell Companies, LLC |
Cornell Corrections Management, LLC |
CCG I, LLC |
Cornell Corrections of Alaska, Inc. |
Cornell Corrections of California, Inc. |
Cornell Corrections of Texas, Inc. |
Cornell Corrections of Rhode Island, Inc. |
Cornell Interventions, Inc. |
Correctional Systems, LLC |
Cornell Abraxas Group, Inc. |
WBP Leasing, LLC |
BII Holding Corporation |
BII Holding I Corporation |
Behavioral Holding Corp. |
Behavioral Acquisition Corp. |
B.I. Incorporated |
MCF GP, LLC |
GEO MCF GP, LLC |
Municipal Corrections Finance, LP |
GEO Operations, LLC |
GEO Corrections Holdings, Inc. |
GEO Corrections and Detention, LLC |
GEO Re-entry Services, LLC |
Cornell Abraxas Group OS, LLC |
Cornell Companies of California OS, LLC |
Cornell Companies of Texas OS, LLC |
Cornell Interventions OS, LLC |
The GEO Group REIT, Inc. |
/s/ Brian R. Evans |
Brian R. Evans |
Principal Financial Officer |