SEC Company Response from Value Line Mid Cap Focused Fund, Inc. (CIK 0000102756) — May 23, 2005
Value Line Mid Cap Focused Fund, Inc. (CIK 0000102756)
Date: May 23, 2005 · CIK: 0000102756 · Accession: 0001144204-05-016809
AI Filing Summary & Sentiment
File numbers found in text: 811-568
Letter
By Edgar May 23, 2005 Mr. Kevin Rupert U.S. Securities and Exchange Commission 450 Fifth Street Washington, DC 20549
Re: The Value Line Fund, Inc. 2-10827/811-568
Dear Mr. Rupert:
This is in response to your comments on the Annual Report filed by the above-noted registrant.
An amended Form N-CSR will be filed showing the mountain chart as requested.
As I indicated to you on the telephone, The Value Line Funds are no longer using Value Line Securities, Inc. for portfolio brokerage.
I have noted your comments that the management discussion should be more descriptive if a fund's performance is less than its benchmark.
The registrant understands that it is responsible for the adequacy and accuracy of the disclosure in the filings; that staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and that the registrant may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
/s/ Peter D. Lowenstein
Legal Counsel
Show Raw Text
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Value Line, Inc.
220 East 42nd Street
New York, NY 10017-5891
By Edgar
May 23, 2005
Mr. Kevin Rupert
U.S. Securities and Exchange Commission
450 Fifth Street
Washington, DC 20549
Re: The Value Line Fund, Inc.
2-10827/811-568
Dear Mr. Rupert:
This is in response to your comments on the Annual Report filed by the
above-noted registrant.
An amended Form N-CSR will be filed showing the mountain chart as
requested.
As I indicated to you on the telephone, The Value Line Funds are no longer
using Value Line Securities, Inc. for portfolio brokerage.
I have noted your comments that the management discussion should be more
descriptive if a fund's performance is less than its benchmark.
The registrant understands that it is responsible for the adequacy and
accuracy of the disclosure in the filings; that staff comments or changes to
disclosure in response to staff comments in the filings reviewed by the staff do
not foreclose the Commission from taking any action with respect to the filing;
and that the registrant may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Very truly yours,
/s/ Peter D. Lowenstein
Legal Counsel
PDL:psp
</TEXT>
</DOCUMENT>