SEC Company Response from AMERICAN STANDARD INC (CIK 0000005850) — Oct 26, 2005
AMERICAN STANDARD INC (CIK 0000005850)
Date: Oct. 26, 2005 · CIK: 0000005850 · Accession: 0000950123-05-012633
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File numbers found in text: 333-124857
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CORRESP
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LETTER TO THE S.E.C.
October 26, 2004
VIA FACSIMILE
Pamela A.
Long, Esq.
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Re: American
Standard Inc., American Standard Companies Inc., American Standard
International Inc.
Form S-4 Registration Statement
(Registration No. 333-124857) (the “Registration
Statement”)
Request for Acceleration of Effectiveness under Rule 461
Dear Ms. Long:
American
Standard Inc., American Standard Companies Inc. and American Standard International
Inc. (collectively, the “Companies”) hereby request that the effective date of the Registration
Statement be accelerated so that it will be declared effective on Thursday, October 27, 2004, or as
soon thereafter as possible.
In
response to the comments of the Staff of the Securities and Exchange Commission (the
“Staff”) commenting on the above-referenced Registration
Statement, the Form 10-K for the period
ended December 31, 2004 and the Form 10-Q for the period ended March 31, 2005 (hereafter, the
“Documents”), the Companies hereby acknowledge that:
•
Should the Securities and Exchange Commission or the Staff,
acting pursuant to delegated authority, declare the filing effective,
it does not foreclose the Securities and Exchange Commission from
taking any action with respect to the filing;
•
The action of the Securities and Exchange Commission or the
Staff, acting pursuant to delegated authority, in declaring the
filing effective, does not relieve the Companies from their full
responsibility for the adequacy and accuracy of the disclosure in the
filing; and
•
the Companies may not assert Staff comments and the
declaration of effectiveness as a defense in any proceeding initiated by the Securities and Exchange
Commission or any person under the federal
securities laws of the United States.
Sincerely,
AMERICAN STANDARD COMPANIES, INC.
By: /s/
Mary Beth Gustafsson
Name: Mary Beth Gustafsson
Title: Senior Vice President, General Counsel
and Secretary