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SEC Company Response from Meritage Homes CORP (MTH) (CIK 0000833079) (MTH) — May 16, 2005

Meritage Homes CORP (MTH) (CIK 0000833079)
Date: May 16, 2005 · CIK: 0000833079 · Accession: 0000950153-05-001172

AI Filing Summary & Sentiment

File numbers found in text: 333-123661

Date
May 16, 2005
Author
Meritage Homes Corporation
Form
CORRESP
Company
Meritage Homes CORP (MTH) (CIK 0000833079)

Letter

VIA EDGAR AND FACSIMILE Securities and Exchange Commission Meritage Homes Corporation and Guarantors listed as Co-registrants Registration Statement on Form S-4 Filed March 29, 2005 File No. 333-123661

Re:

Dear Ladies and Gentlemen:

Meritage Homes Corporation respectfully requests, pursuant to Rule 461 of the General Rules and Regulations of the Securities Act of 1933, as amended, that the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 5:00 p.m., Washington, D.C. time, on May 16, 2005, or as soon thereafter as is practicable.

We acknowledge that (i) the Company is responsible for the adequacy and accuracy of the disclosure in its filings; (ii) Staff comments or changes to disclosure in response to staff comments do not foreclose the United States Securities and Exchange Commission from taking any action with respect to the filing; and (iii) the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the Federal securities laws of the United States.

Very truly yours,
Meritage Homes Corporation

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CORRESP
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corresp

[Meritage Homes Corporation Letterhead]

May 16, 2005

VIA EDGAR AND FACSIMILE

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

    Re:

    Meritage Homes Corporation and Guarantors listed as Co-registrants

    Registration Statement on Form S-4

    Filed March 29, 2005

    File No. 333-123661

Dear Ladies and Gentlemen:

Meritage Homes Corporation respectfully requests, pursuant to Rule 461 of the General Rules and
Regulations of the Securities Act of 1933, as amended, that the above-referenced Registration
Statement be declared effective by the Securities and Exchange Commission at 5:00 p.m., Washington,
D.C. time, on May 16, 2005, or as soon thereafter as is practicable.

We acknowledge that (i) the Company is responsible for the adequacy and accuracy of the disclosure
in its filings; (ii) Staff comments or changes to disclosure in response to staff comments do not
foreclose the United States Securities and Exchange Commission from taking any action with respect
to the filing; and (iii) the Company may not assert Staff comments as a defense in any proceeding
initiated by the Commission or any person under the Federal securities laws of the United States.

Very truly yours,

Meritage Homes Corporation

/s/ Richard T. Morgan

Richard T. Morgan

Vice President and Treasurer