March 22, 2016 Yafit Cohn Simpson Thacher & Bartlett LLP
[email protected] Re: SeaWorld Entertainment, Inc. Dear Ms. Cohn: This is in regard to your letter dated March 21, 2016 concerning the shareholder proposal submitted by People for the Ethical Treatment of Animals for inclusion in SeaWorld’s proxy materials for its upcoming annual meeting of security holders. Your letter indicates that the proponent has withdrawn the proposal and that SeaWorld therefore withdraws its February 8, 2016 request for a no-action letter from the Division. Because the matter is now moot, we will have no further comment. Copies of all of the correspondence related to this matter will be made available on our website at http://www.sec.gov/divisions/corpfin/cf-noaction/14a-8.shtml. For your reference, a brief discussion of the Division’s informal procedures regarding shareholder proposals is also available at the same website address. Sincerely, Evan S. Jacobson Special Counsel cc: Jared S. Goodman PETA Foundation
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[email protected] VIA E-MAIL March 21, 2016 Re: SeaWorld Entertainment, Inc. - Omission of Shareholder Proposal from Proxy Material Pursuant to Rule 14a-8 Office of Chief Counsel Division of Corporation Finance Securities and Exchange Commission 100 F. Street, N .E. Washington, D.C. 20549 Ladies and Gentlemen: This letter serves to inform you that, on behalf of our client, Sea World Entertainment, Inc.