SEC Company Response from BOSTON SCIENTIFIC CORP (BSX) (CIK 0000885725) (BSX) — Mar 1, 2006
BOSTON SCIENTIFIC CORP (BSX) (CIK 0000885725)
Date: March 1, 2006 · CIK: 0000885725 · Accession: 0001047469-06-002713
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File numbers found in text: 333-131608
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[Boston Scientific Letterhead]
March 1,
2006
VIA
EDGAR TRANSMISSION AND FACSIMILE
Securities
and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Perry Hindin
Tim Buchmiller
Request
for Acceleration of Boston Scientific Corporation
Registration Statement on Form S-4 (File No. 333-131608)
Dear
Mr. Hindin:
Pursuant
to Rule 461 of Regulation C, we request that the effective date of the Registration Statement on Form S-4 (File
No. 333-131608) (the "Registration Statement") of Boston Scientific Corporation ("Boston Scientific"), originally filed on February 6, 2006 and the amendment thereto filed on
March 1, 2006, be accelerated to 5:00 p.m. on March 2, 2006, or as soon as possible thereafter.
Boston
Scientific acknowledges that the disclosure in the Registration Statement is the responsibility of Boston Scientific. Boston Scientific also represents to the Securities and
Exchange Commission (the "Commission") that should the Commission or the staff of the Commission (the "Staff"), acting pursuant to its delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing, and Boston Scientific represents that it will not assert this action as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.
Boston
Scientific further acknowledges that the action of the Commission or the Staff, acting pursuant to its delegated authority, in declaring the filing effective does not relieve
Boston Scientific from its full responsibility for the adequacy and accuracy of the disclosures in the filing.
Very truly yours,
BOSTON SCIENTIFIC CORPORATION
By:
/s/ LAWRENCE J. KNOPF Name: Lawrence J. Knopf
Title: Vice President, Assistant General Counsel
cc:Paul
W. Sandman, Boston Scientific Corporation
Bernard E. Kury, Guidant Corporation
Peter D. Lyons, Shearman & Sterling LLP
Clare O'Brien, Shearman & Sterling LLP
Scott D. Petepiece, Shearman & Sterling LLP
Charles W. Mulaney, Jr., Skadden, Arps, Slate, Meagher & Flom LLP
Brian W. Duwe, Skadden, Arps, Slate, Meagher & Flom LLP
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