SEC Company Response from PICO HOLDINGS — Jul 14, 2005
PICO HOLDINGS INC /NEW (CIK 0000830122)
Date: July 14, 2005 · CIK: 0000830122 · Accession: 0000936392-05-000189
AI Filing Summary & Sentiment
File numbers found in text: 333-125362
Letter
United States Securities and Exchange Commission Attn: Kate McHale Re: PICO Holdings, Inc. Amendment No. 1 to Registration Statement on Form S-3 (File No. 333-125362)
Dear Ms. McHale:
On behalf of PICO Holdings, Inc. (the “Company”), I hereby request that the Commission take appropriate action to make the above-captioned Registration Statement effective at 9:00 a.m. Washington, D.C. Time, on July 15, 2005, or as soon thereafter as practicable. The Company acknowledges that:
•
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 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.
Sincerely,
/s/ James F. Mosier, Esq.
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CORRESP
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corresp
PICO Holdings, Inc.
875 Prospect Street, Suite 301
La Jolla, California 92037
July 13, 2005
Via Facsimile [(202) 772-9208] and EDGAR
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Mail Stop 4561
Washington, D.C. 20549
Attn: Kate McHale
Re:
PICO Holdings, Inc.
Amendment No. 1 to Registration Statement on Form S-3 (File No. 333-125362)
Dear Ms. McHale:
On behalf of PICO Holdings, Inc. (the “Company”), I hereby request that the Commission take
appropriate action to make the above-captioned Registration Statement effective at 9:00 a.m.
Washington, D.C. Time, on July 15, 2005, or as soon thereafter as practicable. The Company
acknowledges that:
•
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 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.
Sincerely,
/s/ James F. Mosier, Esq.
James F. Mosier, Esq.
General Counsel
cc:
Douglas J. Rein, Esq.
Marty B. Lorenzo, Esq.