SEC Company Response from SPESCOM SOFTWARE INC (CIK 0000813747) — Mar 21, 2005
SPESCOM SOFTWARE INC (CIK 0000813747)
Date: March 21, 2005 · CIK: 0000813747 · Accession: 0001047469-05-007217
AI Filing Summary & Sentiment
File numbers found in text: 333-121038
Letter
Re:Spescom Software Inc.
March 21, 2005
Via FACSIMILE and EDGAR
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Barbara Jacobs
Registration Statement on Form S-2 (File No. 333-121038)
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Spescom Software Inc. (the "Company") respectfully requests the acceleration of the effectiveness of the above-referenced Registration Statement on Form S-2, as amended, so as to become effective at 9:00 a.m. (EST) on March 22, 2005, or as soon as possible thereafter.
Pursuant to the December 29, 2004 comments of the staff of the Securities and Exchange Commission, the Company hereby acknowledges the following:
•should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
•the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
•the Company may not assert the 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.
Thank you for your assistance and please contact Russell Hansen of Gibson, Dunn & Crutcher LLP at (650) 849-5383 if you have any questions or comments.
Sincerely,
/s/ JOHN W. LOW John W. Low
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CORRESP
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filename1.htm
March 21, 2005
Via FACSIMILE and EDGAR
Securities
and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Barbara Jacobs
Re:Spescom Software Inc.
Registration Statement on Form S-2 (File No. 333-121038)
Ladies
and Gentlemen:
Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Spescom Software Inc. (the "Company") respectfully requests the acceleration of the
effectiveness of the above-referenced Registration Statement on Form S-2, as amended, so as to become effective at 9:00 a.m. (EST) on March 22, 2005, or as soon as
possible thereafter.
Pursuant
to the December 29, 2004 comments of the staff of the Securities and Exchange Commission, the Company hereby acknowledges the following:
•should
the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;
•the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and
•the
Company may not assert the 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.
Thank
you for your assistance and please contact Russell Hansen of Gibson, Dunn & Crutcher LLP at (650) 849-5383 if you have any questions or comments.
Sincerely,
/s/ JOHN W. LOW John W. Low
Secretary and Chief Financial Officer