SEC Company Response from BIRCH BRANCH INC (CIK 0000857872) — Nov 8, 2005
BIRCH BRANCH INC (CIK 0000857872)
Date: Nov. 8, 2005 · CIK: 0000857872 · Accession: 0001011034-05-000231
AI Filing Summary & Sentiment
File numbers found in text: 333-126654
Letter
CLIFFORD L. NEUMAN, P.C.
Attorney at Law
TEMPLE-BOWRON HOUSE
1507 PINE STREET
BOULDER, COLORADO 80302
Telephone: (303) 449-2100
Facsimile: (303) 449-1045
E-mail: clneuman@neuman.com
November 8, 2005
VIA EDGAR AND FEDERAL EXPRESS
United States Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 0409
Washington, D.C. 20549
Attn:
Ms. Karen J. Garnett
Mr. Matthew Maulbeck
Mr. Steven Jacobs
Mr. David Roberts
Re:
Birch Branch, Inc.
Registration Statement on Form SB-2, Amendment No. 2
Filed November 7, 2005
File No. 333-126654
Ladies and Gentlemen:
On behalf of Birch Branch Inc., a Colorado corporation ("Birch Branch"), filed herewith is Amendment No. 2 ("Amendment No. 2") to the Registration Statement (Securities and Exchange Commission file number 333-126654) filed by Birch Branch on July 15, 2005 (the "Registration Statement"). This letter responds to the comments of the staff (the "Staff") of the Securities and Exchange Commission (the "Commission") addressed to Mr. Michael Schumacher, President of Birch Branch, and transmitted to the undersigned on November 2, 2005, regarding the Registration Statement. The enclosed Amendment No. 2 has been marked to show changes from Amendment No. 1 to the Registration Statement.
Birch Branch's responses to the Staff's comments are set forth below and are numbered to correspond to the numbering of the Staff's comments in the Staff's letter of November 2, 2005. Unless otherwise indicated, all references to page numbers in the responses below refer to page numbers in the blacklined version of Amendment No. 2. The responses provided herein are based on discussions with, and information furnished by, Birch Branch, Inc. and their respective advisors.
General
Comment 1: Revised as suggested. See page 13.
Comment 2: Revised as suggested. See page 18.
Comment 3: Revised as suggested. See page 18.
Comment 4: Revised as suggested. See page 20.
Comment 5: Revised as suggested. See page F-8.
Comment 6: Revised as suggested. See page 26.
Comment 7: Revised as suggested. See Exhibit 5.0.
Sincerely,
/s/ Clifford L. Neuman
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CORRESP
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CLIFFORD L. NEUMAN, P.C.
Attorney at Law
TEMPLE-BOWRON HOUSE
1507 PINE STREET
BOULDER, COLORADO 80302
Telephone: (303) 449-2100
Facsimile: (303) 449-1045
E-mail: clneuman@neuman.com
November 8, 2005
VIA EDGAR AND FEDERAL EXPRESS
United States Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 0409
Washington, D.C. 20549
Attn:
Ms. Karen J. Garnett
Mr. Matthew Maulbeck
Mr. Steven Jacobs
Mr. David Roberts
Re:
Birch Branch, Inc.
Registration Statement on Form SB-2, Amendment No. 2
Filed November 7, 2005
File No. 333-126654
Ladies and Gentlemen:
On behalf of Birch Branch Inc., a Colorado corporation ("Birch Branch"), filed herewith is Amendment No. 2 ("Amendment No. 2") to the Registration Statement (Securities and Exchange Commission file number 333-126654) filed by Birch Branch on July 15, 2005 (the "Registration Statement"). This letter responds to the comments of the staff (the "Staff") of the Securities and Exchange Commission (the "Commission") addressed to Mr. Michael Schumacher, President of Birch Branch, and transmitted to the undersigned on November 2, 2005, regarding the Registration Statement. The enclosed Amendment No. 2 has been marked to show changes from Amendment No. 1 to the Registration Statement.
Birch Branch's responses to the Staff's comments are set forth below and are numbered to correspond to the numbering of the Staff's comments in the Staff's letter of November 2, 2005. Unless otherwise indicated, all references to page numbers in the responses below refer to page numbers in the blacklined version of Amendment No. 2. The responses provided herein are based on discussions with, and information furnished by, Birch Branch, Inc. and their respective advisors.
General
Comment 1:
Revised as suggested. See page 13.
Comment 2: Revised as suggested. See page 18.
Comment 3: Revised as suggested. See page 18.
Comment 4: Revised as suggested. See page 20.
Comment 5: Revised as suggested. See page F-8.
Comment 6: Revised as suggested. See page 26.
Comment 7: Revised as suggested. See Exhibit 5.0.
Sincerely,
/s/ Clifford L. Neuman
Clifford L. Neuman
cc: Michael Schumacher