SEC Company Response from URS — Nov 21, 2005
URS CORP /NEW/ (CIK 0000102379)
Date: Nov. 21, 2005 · CIK: 0000102379 · Accession: 0000950149-05-000697
AI Filing Summary & Sentiment
File numbers found in text: 333-129266
Referenced dates: November 15, 2005
Letter
Via EDGAR and Federal Express Division of Corporation Finance Mail Stop 7010 Washington, DC 20549-7010 Re: URS Corporation
Dear Ms. Long:
On behalf of our client, URS Corporation (“URS”), we are transmitting to you this letter in response to a comment received from the staff of the Securities and Exchange Commission (the “Commission”), by letter dated November 15, 2005, with respect to the Registration Statement on Form S-3, File No. 333-129266, filed with the Commission on October 27, 2005. Comment No. 14 requested the following:
Please have counsel confirm to us that it concurs with our understanding that its reference to the “Delaware General Corporation Law” includes the statutory provisions and all applicable provisions of the Delaware Constitution and any reported judicial decisions interpreting these laws. Please have counsel file this confirmation as correspondence on EDGAR.
We hereby confirm that the reference in our legality opinion to the Delaware General Corporation Law is meant to encompass relevant portions of the Delaware Constitution and published judicial proceedings of Delaware courts.
Please do not hesitate to call me at (415) 693-2113 if you have any questions or would like any additional information regarding this matter.
Sincerely,
/s/ Samuel M. Livermore
Show Raw Text
CORRESP
1
filename1.htm
corresp
ATTORNEYS AT LAW
Broomfield, CO
720 566-4000
Palo Alto, CA
101 California Street
650 843-5000
5th Floor
San Francisco, CA
Reston, VA
94111-5800
Main 415 693-2000
Fax 415 693-2222
703 456-8000
San Diego, CA
858 550-6000
November 21, 2005
www.cooley.com
Washington, DC
202 842-7800
SAMUEL M. LIVERMORE
Via EDGAR and Federal Express
(415) 693-2113
slivermore@cooley.com
Pamela A. Long
Assistant Director
U.S. Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 7010
Washington, DC 20549-7010
Re: URS Corporation
Dear Ms. Long:
On behalf of our client, URS Corporation (“URS”), we are transmitting to you this letter in
response to a comment received from the staff of the Securities and Exchange Commission (the
“Commission”), by letter dated November 15, 2005, with respect to the Registration Statement on
Form S-3, File No. 333-129266, filed with the Commission on October 27, 2005. Comment No. 14
requested the following:
Please have counsel confirm to us that it concurs with our
understanding that its reference to the “Delaware General Corporation Law”
includes the statutory provisions and all applicable provisions of the
Delaware Constitution and any reported judicial decisions interpreting these
laws. Please have counsel file this confirmation as correspondence on
EDGAR.
We hereby confirm that the reference in our legality opinion to the Delaware General Corporation
Law is meant to encompass relevant portions of the Delaware Constitution and published judicial
proceedings of Delaware courts.
Please do not hesitate to call me at (415) 693-2113 if you have any questions or would like any
additional information regarding this matter.
Sincerely,
/s/ Samuel M. Livermore
Samuel M. Livermore
973204 v1/SF