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SEC Company Response from T BAY HOLDINGS INC (CIK 0000868689) — Sep 2, 2005

T BAY HOLDINGS INC (CIK 0000868689)
Date: Sept. 2, 2005 · CIK: 0000868689 · Accession: 0001078782-05-000378

AI Filing Summary & Sentiment

Referenced dates: August 24, 2005

Date
August 29, 2005
Author
/s/ Cletha A. Walstrand
Form
CORRESP
Company
T BAY HOLDINGS INC (CIK 0000868689)

Letter

United States Securities and Exchange Commission Division of Corporation Finance Washington, DC 20549 Re: T Bay Holdings, Inc. File No. 033-37099-S

Dear Mr. Bhandari:

T-Bay Holdings, Inc. (the “Company”), has received your comment letter dated August 24, 2005, (“comment letter”) pertaining to the Form 8-K filed August 18, 2005 and in particular regarding Item 4.01.

We have amended the Form 8-K, Item 4.01 in response to your comments numbered 1 through 4. In addition the Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the filing and that staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing. Further the Company acknowledges it 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.

If you have any questions or require additional information, please notify me directly.

Very truly yours,
/s/ Cletha A. Walstrand

Show Raw Text
CORRESP
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02/18/05 fRI 19: 14 FAX 202 942 9527

Cletha A. Walstrand

Attorney at Law

8 East Broadway, Suite 609

Salt Lake City, UT 84111

Office: 801-363-0890     Fax: 801-363-8512

cwalstrand@networld.com

August 29, 2005

Brian K. Bhandari

United States Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, DC  20549

Re:

T Bay Holdings, Inc.

File No. 033-37099-S

Dear Mr. Bhandari:

T-Bay Holdings, Inc. (the “Company”), has received your comment letter dated August 24, 2005, (“comment letter”) pertaining to the Form 8-K filed August 18, 2005 and in particular regarding Item 4.01.

We have amended the Form 8-K, Item 4.01 in response to your comments numbered 1 through 4.  In addition the Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the filing and that staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing.  Further the Company acknowledges it 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.

If you have any questions or require additional information, please notify me directly.

Very truly yours,

/s/ Cletha A. Walstrand

Cletha A. Walstrand

Attorney at Law

enclosures