RB Global Inc.
Response of the Office International Corporate Finance
Division of Corporation Finance
February 27, 2026
Re: RB Global Inc.
Incoming letter dated February 27, 2026
Dear Mr. Breheny:
Based on the facts presented, the Division of Corporation Finance will not object if RB Global Inc. were to file a definitive proxy statement without filing a preliminary proxy statement for the proposals, as described in your incoming letter, that are required to be submitted for shareholder approval at an annual meeting under the laws of Ontario, Canada. Foreign issuers organized under the laws of Ontario may rely on this letter with respect to the proposals described in your incoming letter.
This position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion.
Sincerely,
/s/ Michael Coco
Michael Coco
Chief, Office of International Corporate Finance
Division of Corporation Finance
Last Reviewed or Updated: March 30, 2026