SEC Company Response from JOY GLOBAL INC (CIK 0000801898) — Apr 13, 2005

JOY GLOBAL INC (CIK 0000801898)
Date: April 13, 2005 · CIK: 0000801898 · Accession: 0000801898-05-000084

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File numbers found in text: 333-121569

Date

April 13, 2005

Author

Not clearly detected

Form

CORRESP

Company

JOY GLOBAL INC (CIK 0000801898)

Letter

Re: Joy Global Inc. (the “Company”) Registration Statement on Form S-3

JOY GLOBAL INC. 100 East Wisconsin Ave,

Suite 2780 Milwaukee, Wisconsin 53202

April 13, 2005

VIA FACSIMILE (202) 942-9585 AND EDGAR Securities and Exchange Commission 450 Fifth Plaza, N.W. Judiciary Plaza Washington, D.C. 20549

Attention: Mary Beth Breslin

(SEC File No. 333-121569) Originally Filed December 23, 2004

Ladies and Gentlemen:

The Company hereby requests acceleration of the effective date of its Registration Statement on Form S-3 (SEC File No. 333-121569), as amended, to 4:00 p.m., Washington, D.C. time, on April 15, 2005 or as soon thereafter as possible.

The Company hereby acknowledges its responsibilities under the Securities Act of 1933, as amended, as they relate to an offering of the securities pursuant to the above-referenced Registration Statement.

Please call John Jennings or Keith Crow of Kirkland & Ellis LLP, special counsel to the Company, at (312) 861-2267 and (312) 861-2181, respectively, as soon as the Registration Statement has been declared effective.

Very truly yours,
Joy Global Inc.

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CORRESP
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JOY GLOBAL INC.
100 East Wisconsin Ave,

Suite 2780
Milwaukee, Wisconsin 53202

April 13, 2005

VIA FACSIMILE (202) 942-9585
AND EDGAR
Securities and Exchange Commission
450 Fifth Plaza,
N.W.
Judiciary Plaza
Washington, D.C. 20549

Attention: Mary Beth
Breslin

Re:
Joy Global Inc. (the “Company”)
Registration Statement on Form S-3

(SEC File No. 333-121569) Originally Filed December 23, 2004

Ladies and Gentlemen:

        The
Company hereby requests acceleration of the effective date of its Registration Statement
on Form S-3 (SEC File No. 333-121569), as amended, to 4:00 p.m., Washington, D.C. time, on
April 15, 2005 or as soon thereafter as possible.

        The
Company hereby acknowledges its responsibilities under the Securities Act of 1933, as
amended, as they relate to an offering of the securities pursuant to the above-referenced
Registration Statement.

        Please
call John Jennings or Keith Crow of Kirkland & Ellis LLP, special counsel to
the Company, at (312) 861-2267 and (312) 861-2181, respectively, as soon as the
Registration Statement has been declared effective.

     Very truly yours,

Joy Global Inc.

          By: Oren B. Azar

     Name: Oren B. Azar

     Its:  Secretary and Associate General Counsel

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