SEC Company Response from RUBY MINING CO (CIK 0000085684) — Dec 15, 2005
RUBY MINING CO (CIK 0000085684)
Date: Dec. 15, 2005 · CIK: 0000085684 · Accession: 0001028269-05-000049
AI Filing Summary & Sentiment
File numbers found in text: 333-128584
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ADMIRALTY HOLDING COMPANY
3318 Hwy 5, #504 Douglasville, GA 30135-2308
877-948-7327 Toll free and fax
Admiraltycorp@mindspring.com
www.admiraltycorporation.com
December 15, 2005
VIA EDGAR AND FACSIMILE TRANSMISSION (202-772-9369)
United States Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-7010
Attention: Mr. H. Roger Schwall
Mr. Jason Wynn
RE: ADMIRALTY HOLDING COMPANY (FORMERLY KNOWN AS RUBY MINING
COMPANY)
REGISTRATION STATEMENT ON FORM SB-2
REGISTRATION NO. 333-128584
Dear Messrs. Schwall and Wynn:
Pursuant to the provisions of Rule 461 under the Securities Act of 1933, as
amended, Admiralty Holding Company, formerly known as Ruby Mining Company, (the
"Company") respectfully requests acceleration of the effective date of its
above-referenced Registration Statement on Form SB-2 (File No. 333-128584) to
Tuesday, December 20, 2005, at 2:00 p.m., (Eastern standard time), or a soon
thereafter as is reasonably practicable.
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.
The Company is aware of its responsibilities under the Securities Act of
1933, as amended, and the Securities Exchange Act of 1934, as amended, as they
relate to the filing.
Very truly yours,
/s/ Murray D. Bradley, Jr
Murray D. Bradley, Jr.
Chief Financial Officer
Admiralty Holding Company (formerly Ruby Mining Company)
cc: G. Howard Collingwood
Chief Executive Officer
Steven A. Cunningham, Esq.
Corporate Counsel
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