SEC Company Response from Ventas, Inc. (VTR) (CIK 0000740260) (VTR) — Sep 7, 2005
Ventas, Inc. (VTR) (CIK 0000740260)
Date: Sept. 7, 2005 · CIK: 0000740260 · Accession: 0001047469-05-022636
AI Filing Summary & Sentiment
File numbers found in text: 333-127262
Referenced dates: August 16, 2005
Letter
VIA EDGAR AND FEDERAL EXPRESS Securities and Exchange Commission Assistant Director Division of Corporation Finance Re:Registration Statement on Form S-4 filed on August 5, 2005 File No. 333-127262
Dear Ms. Garnett:
On behalf of Ventas Realty, Limited Partnership and Ventas Capital Corporation (together, the "Issuers"), Ventas, Inc. ("Ventas") and the other Guarantors (the "Guarantors," and together with the Issuers and Ventas, the "Registrants") named in the above-referenced registration statement on Form S-4 filed by the Registrants with the Securities and Exchange Commission (the "Commission") on August 5, 2005 (the "Registration Statement"), set forth below is the Registrants' response to the comment of the staff (the "Staff") of the Commission contained in the letter dated August 16, 2005 (the "Comment Letter") from you to T. Richard Riney, Executive Vice President, General Counsel and Secretary of Ventas, with respect to the Registration Statement.
For the convenience of the Staff, set forth below in italics is the Staff's comment from the Comment Letter, immediately followed by the Registrants' response thereto.
1.Please revise to include the undertakings required by Item 512(a) of Regulation S-K.
On September 7, 2005, the Registrants filed with the Commission in electronic format via EDGAR Amendment No. 1 to the Registration Statement (the "Amendment"). The Registrants have revised the Registration Statement to include the undertakings required by Item 512(a) of Regulation S-K. Such undertakings have been included by the Registrants in Part II, Item 22 of the Amendment on page II-34 thereof.
Should you or any member of the Staff have any questions or comments or wish to discuss further the Registrants' response to the Comment Letter, please call me at (212) 728-8597.
Very
truly yours,
/s/
Nicole G. Roth
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[LETTERHEAD OF WILLKIE FARR & GALLAGHER LLP]
September 7,
2005
VIA EDGAR AND FEDERAL EXPRESS
Securities
and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attn:Karen
J. Garnett
Assistant Director
Division of Corporation Finance
Re:Registration Statement on Form S-4 filed on August 5, 2005
File No. 333-127262
Dear
Ms. Garnett:
On
behalf of Ventas Realty, Limited Partnership and Ventas Capital Corporation (together, the "Issuers"), Ventas, Inc. ("Ventas") and the other Guarantors (the "Guarantors," and
together with the Issuers and Ventas, the "Registrants") named in the above-referenced registration statement on Form S-4 filed by the Registrants with the Securities and Exchange
Commission (the "Commission") on August 5, 2005 (the "Registration Statement"), set forth below is the Registrants' response to the comment of the staff (the "Staff") of the Commission
contained in the letter dated
August 16, 2005 (the "Comment Letter") from you to T. Richard Riney, Executive Vice President, General Counsel and Secretary of Ventas, with respect to the Registration Statement.
For
the convenience of the Staff, set forth below in italics is the Staff's comment from the Comment Letter, immediately followed by the Registrants' response thereto.
1.Please revise to include the undertakings required by Item 512(a) of Regulation S-K.
On
September 7, 2005, the Registrants filed with the Commission in electronic format via EDGAR Amendment No. 1 to the Registration Statement (the "Amendment"). The Registrants have
revised the Registration Statement to include the undertakings required by Item 512(a) of Regulation S-K. Such undertakings have been included by the Registrants in Part II,
Item 22 of the Amendment on page II-34 thereof.
Should
you or any member of the Staff have any questions or comments or wish to discuss further the Registrants' response to the Comment Letter, please call me at
(212) 728-8597.
Very
truly yours,
/s/
Nicole G. Roth
Nicole
G. Roth
cc:T.
Richard Riney, Ventas, Inc.
Leslie M. Mazza, Esq., Willkie Farr & Gallagher LLP