SEC Comment Letter for SEA PINES ASSOCIATES INC (CIK 0000846926) — Sep 14, 2004
SEA PINES ASSOCIATES INC (CIK 0000846926)
Date: Sept. 14, 2004 · CIK: 0000846926 · Accession: 0000000000-04-029473
AI Filing Summary & Sentiment
File numbers found in text: 000-17517
Letter
September 14, 2004 Mail Stop 0409 Steve Birdwell Chief Financial Officer Sea Pines Associates, Inc. 32 Greenwood Drive Hilton Head Island, South Carolina 29928
Re: Sea Pines Associates, Inc. Schedule 14A Filed: August 16, 2004 File No. 000-17517
Dear Mr. Birdwell: We note your supplemental response to our comment. Because Riverstone Group owns 26.61% of Sea Pines` common stock, Riverstone Group appears to be an affiliate of the issuer. As such, it appears appropriate to file a Schedule 13E-3 in connection with the proposed transaction. Please revise to do so, or advise us why you believe it is appropriate under the federal securities laws not to do so.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing(s) to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Additionally, the registrant should provide written acknowledgement of the following:
The adequacy and accuracy of the disclosure in the filing is the responsibility of the registrant. The registrant acknowledges that staff comment or changes in response to staff comment in the proposed disclosure in the Information Statement do not foreclose the Commission from taking any action with respect to the filing. The registrant also represents that staff comment may not be asserted as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing.
Please contact Jeffrey Shady, Staff Attorney, at (202) 942-1901 or the undersigned at (202) 942-1903 with any other questions. Sincerely,
Paul Fischer Attorney-Advisor Sea Pines Associates, Inc. Page 1
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> September 14, 2004 Mail Stop 0409 Steve Birdwell Chief Financial Officer Sea Pines Associates, Inc. 32 Greenwood Drive Hilton Head Island, South Carolina 29928 Re: Sea Pines Associates, Inc. Schedule 14A Filed: August 16, 2004 File No. 000-17517 Dear Mr. Birdwell: We note your supplemental response to our comment. Because Riverstone Group owns 26.61% of Sea Pines` common stock, Riverstone Group appears to be an affiliate of the issuer. As such, it appears appropriate to file a Schedule 13E-3 in connection with the proposed transaction. Please revise to do so, or advise us why you believe it is appropriate under the federal securities laws not to do so. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing(s) to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Additionally, the registrant should provide written acknowledgement of the following: The adequacy and accuracy of the disclosure in the filing is the responsibility of the registrant. The registrant acknowledges that staff comment or changes in response to staff comment in the proposed disclosure in the Information Statement do not foreclose the Commission from taking any action with respect to the filing. The registrant also represents that staff comment may not be asserted as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing. Please contact Jeffrey Shady, Staff Attorney, at (202) 942-1901 or the undersigned at (202) 942-1903 with any other questions. Sincerely, Paul Fischer Attorney-Advisor Sea Pines Associates, Inc. Page 1 </TEXT> </DOCUMENT>