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SEC Company Response from TEJON RANCH CO (TRC) (CIK 0000096869) (TRC) — May 14, 2010

TEJON RANCH CO (TRC) (CIK 0000096869)
Date: May 14, 2010 · CIK: 0000096869 · Accession: 0001193125-10-120669

AI Filing Summary & Sentiment

File numbers found in text: 333-166167

Date
May 14, 2010
Author
Walker
Form
CORRESP
Company
TEJON RANCH CO (TRC) (CIK 0000096869)

Letter

VIA EDGAR AND HAND DELIVERY Division of Corporation Finance Re: Tejon Ranch Co. Registration Statement on Form S-3 Filed April 19, 2010 File No. 333-166167

Dear Ms. Martin:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Tejon Ranch Co., a Delaware corporation (the “Company”), hereby respectfully requests that the effective time of the above referenced Registration Statement on Form S-3 filed by the Company (the “Registration Statement”) be accelerated to 1 p.m., Eastern Standard Time, on May 17, 2010 or as soon thereafter as practicable.

The Company hereby acknowledges that:

•

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; 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.

[Signature page follows]

Very truly yours,
/s/ Carla
Walker

Show Raw Text
CORRESP
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filename1.htm

Acceleration Request

 [Tejon Ranch Co. Letterhead]

May 14, 2010

VIA EDGAR AND HAND DELIVERY

Erin E. Martin

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

100 F Street, N.E.

 Mail Stop 3010

Washington, D.C. 20549

Re:
Tejon Ranch Co.

Registration Statement on Form S-3

Filed April 19, 2010

File No. 333-166167

 Dear
Ms. Martin:

 Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Tejon Ranch Co., a
Delaware corporation (the “Company”), hereby respectfully requests that the effective time of the above referenced Registration Statement on Form S-3 filed by the Company (the “Registration Statement”) be accelerated to 1 p.m.,
Eastern Standard Time, on May 17, 2010 or as soon thereafter as practicable.

 The Company hereby acknowledges that:

•

 should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the
Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

•

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; 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.

 [Signature page follows]

 Very truly yours,

/s/ Carla
Walker

 Carla Walker

 Vice
President & Controller of

 Tejon Ranch Co.

cc:
Tom Kluck

Mark Lahive, Gibson, Dunn & Crutcher LLP

 2