SEC Company Response from REGENCY CENTERS CORP (REG, REGCO, REGCP) (CIK 0000910606) (REG) — Jan 6, 2005
REGENCY CENTERS CORP (REG, REGCO, REGCP) (CIK 0000910606)
Date: Jan. 6, 2005 · CIK: 0000910606 · Accession: 0000897069-05-000075
AI Filing Summary & Sentiment
Letter
WRITER'S DIRECT LINE 904.359.8713 lkelso@foley.com EMAIL CLIENT/MATTER NUMBER 040521-0109 VIA EDGAR Ms. Christina Chalk, Special Counsel Securities and Exchange Commission Division of Corporation Finance Office of Mergers and Acquisitions 450 Fifth Street, N.W. Washington, DC 20549
Re: Regency Centers Corporation Schedule TO-I/A filed January 5, 2005 SEC File No. 5-42731
Dear Ms. Chalk:
This letter is in response to our telephone conversations earlier today concerning Regency's Schedule TO-I/A filed yesterday. Contemporaneously herewith, Regency is filing Amendment No. 2 to Schedule TO in response to your comment on the new disclosures about dispute resolution.
As indicated in Amendment No. 2, the last paragraph under "Dispute Resolution" on page 17 of the Offer to Exchange has been amended to read in full as follows (new language is double-underscored, and deleted language is stricken through in non-EDGAR version):
"Claims under federal securities law may not be subject to mandatory arbitration, as the Securities and Exchange Commission deems the attempt to limit judicial remedies to be against public policy and therefore unenforceable."
Regency is disseminating later today to all eligible participants a full copy of the Supplement filed yesterday, with the new language above substituted for the language set forth in yesterday's filing on page 17.
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Securities and Exchange Commission January 6, 2005 Page 2
If you have any further questions, please do not hesitate to contact me.
Very truly yours,
/s/ Linda Y. Kelso
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:FOLEY
FOLEY & LARDNER LLP
ATTORNEYS AT LAW
One Independent Drive, Suite 1300
January 6, 2005 Jacksonville, FL 32202-5017
P. O. Box 240
Jacksonville, FL 32201-0240
904.359.2000 TEL
904.359.8700 FAX
www.foley.com
WRITER'S DIRECT LINE
904.359.8713
lkelso@foley.com EMAIL
CLIENT/MATTER NUMBER
040521-0109
VIA EDGAR
Ms. Christina Chalk, Special Counsel
Securities and Exchange Commission
Division of Corporation Finance
Office of Mergers and Acquisitions
450 Fifth Street, N.W.
Washington, DC 20549
Re: Regency Centers Corporation
Schedule TO-I/A filed January 5, 2005
SEC File No. 5-42731
Dear Ms. Chalk:
This letter is in response to our telephone conversations
earlier today concerning Regency's Schedule TO-I/A filed yesterday.
Contemporaneously herewith, Regency is filing Amendment No. 2 to Schedule TO in
response to your comment on the new disclosures about dispute resolution.
As indicated in Amendment No. 2, the last paragraph under
"Dispute Resolution" on page 17 of the Offer to Exchange has been amended to
read in full as follows (new language is double-underscored, and deleted
language is stricken through in non-EDGAR version):
"Claims under federal securities law may not be
subject to mandatory arbitration, as the Securities and
Exchange Commission deems the attempt to limit judicial
remedies to be against public policy and therefore
unenforceable."
Regency is disseminating later today to all eligible
participants a full copy of the Supplement filed yesterday, with the new
language above substituted for the language set forth in yesterday's filing on
page 17.
<PAGE>
Securities and Exchange Commission
January 6, 2005
Page 2
If you have any further questions, please do not hesitate to
contact me.
Very truly yours,
/s/ Linda Y. Kelso
Linda Y. Kelso
LYK/bmj
cc: Mr. J. Christian Leavitt
Mr. Brian Fraser
Ms. Jamie Fegan Conroy
Ms. Celia Paulk
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