SEC Company Response from ACCURIDE CORP (CIK 0000817979) — Apr 14, 2005
ACCURIDE CORP (CIK 0000817979)
Date: April 14, 2005 · CIK: 0000817979 · Accession: 0001047469-05-010211
AI Filing Summary & Sentiment
File numbers found in text: 333-121944
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CORRESP
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Accuride Corporation
7140 Office Circle
Evansville, Indiana 47715
April 14, 2005
VIA FACSIMILE AND EDGAR TRANSMISSION
Max A. Webb
Assistant Director
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0303
Re:
Accuride Corporation
Registration Statement on Form S-1
File No. 333-121944
Ladies and Gentlemen:
In accordance with
Rule 461 under the Securities Act of 1933, we hereby request acceleration of
the effective date of the Registration Statement on Form S-1 (No. 333-121944) (the “Registration Statement”)
of Accuride Corporation (the “Registrant”). We respectfully request that the Registration
Statement become effective as of 2:00 p.m., Washington, D.C. time, on April 18,
2005, or as soon as practicable thereafter.
Once the Registration Statement has been declared effective, please
orally confirm that event with our counsel, Latham & Watkins LLP, by
calling Mark Roeder at (650) 463-3043.
We also respectfully request that a copy of the written order from the
Securities and Exchange Commission (the "Commission") verifying the
effective time and date of the Registration Statement be sent to our counsel,
Latham & Watkins LLP, Attention: Mark Roeder, by facsimile to (650)
463-2600.
The Company 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 this action as a defense in
any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Please do not
hesitate to call Mr. Roeder at (650) 463-3043 if you have any questions
regarding this request.
Very truly yours,
/s/David K. Armstrong
David K. Armstrong
Senior Vice President/General Counsel and
Corporate Secretary
April 14, 2005
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: Accuride Corporation
Common Stock
File No. 333-121944, Form S-1
Dear Sirs:
In
connection with the proposed offering of the above-captioned Securities, we
wish to advise you that we hereby join with the Registrant’s request that the
effective date of the above-captioned Registration Statement be accelerated so
that the same will become effective on
April
18, 2005 at 2:00 p.m. or as soon as practicable thereafter.
Supplemental information supplied under Rule 418(a)(7) under the
Securities Act of 1933:
(i)
Date of Preliminary Prospectus: April 1, 2005
(ii)
Dates of distribution: April 1, 2005 — April 7, 2005
(iii)
Number of prospective underwriters: 8
(iv)
Number of prospectuses distributed under (iii)
above: approximately 27,500
(v)
Compliance with Rule 15c2-8 under the Securities
Exchange Act of 1934: Included in Master Agreement Among Underwriters of
Salomon Smith Barney Inc. (now known as Citigroup Global Markets Inc.).
Very truly yours,
Citigroup Global Markets Inc.
/s/ John C. Cocchiarella
John C. Cocchiarella
Vice President and Associate General Counsel