SEC Company Response from JAMESON INNS INC (CIK 0000914373) — Jun 3, 2005
JAMESON INNS INC (CIK 0000914373)
Date: June 3, 2005 · CIK: 0000914373 · Accession: 0001193125-05-120217
AI Filing Summary & Sentiment
File numbers found in text: 333-119016
Letter
Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549 Re: Jameson Inns, Inc. Amendment No.2 to Form S-3 filed December 30, 2004 File No. 333-119016
Dear Jeff:
This letter is being submitted pursuant to your request. The purpose of this letter is to explain the procedures which Jameson Inns, Inc. (the “Company”) agrees to implement regarding electronic delivery of documents in the Jameson Stock Awards Program (the “Program”). This is the issue addressed in comment no. 4 of your January 28, 2005 comment letter and in the draft of our proposed response which was submitted to you on February 10, 2005. It is proposed that each prospectus will be amended to incorporate the terms discussed below and our response to your January 28, 2005 comment letter will be appropriately revised from the draft previously submitted to you.
When participants enroll in the Program, they will receive both the Frequent Guest Loyalty Program and Direct Stock Purchase Plan prospectuses along with the enrollment form. If the enrollment form is written, the enrollees will receive written copies of the final prospectuses. If they enroll online, there will be links to each of the final prospectuses.
The enrollment form will require that each enrollee consent to electronic delivery of all of the documents related to the offering, which would include any amendments or supplements to
February 21, 2005
Page 2
the final prospectuses and copies of the final prospectuses, each time shares are issued to the participant in the Program. This consent will also provide that unless and until it is revoked, all subsequent shareholder materials and communications may be delivered electronically as well. However, the consent to delivery of subsequent materials and communications (as opposed to the documents relating just to the offering of the shares) will be revocable and that fact will be noted on the form. Upon revocation, the participant will begin receiving written copies of these materials. Participation in the Program will not be terminated because of a participant’s revocation of consent to electronic delivery of these materials. The participant will continue to receive shareholder materials in hard copy via U. S. mail.
Further, participants will be sent confirmations electronically each time shares are credited to their Program accounts for hotel stay credits or for direct stock purchases. These confirmations will comply with Rule 10b-10 of the Securities Exchange Act, as amended, and will have links to the final prospectuses, including any amendments and supplements that might then be applicable.
We hope that this letter clarifies the revised terms of the Program as we discussed on the telephone. If you have further questions or comments, please do not hesitate to call me directly.
Yours very truly,
/s/ Lynn
Lynnwood R. Moore, Jr.
Cc: Jameson Inns, Inc.
Brinson Patrick Securities Corporation
Lehman & Eilen LLP
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CORRESP
1
filename1.htm
Correspondence
CONNER & WINTERS
TULSA
ATTORNEYS & COUNSELORS AT LAW
William G. von Glahn
Vicki Bronson*
Henry G. Will
Joseph J. McCain, Jr.
Lynnwood R. Moore, Jr.
Robert A. Curry
Steven W. McGrath
D. Richard Funk
Randolph L. Jones, Jr.
J. Ronald Petrikin
Larry B. Lipe
James E. Green, Jr.
Martin R. Wing
John W. Ingraham
Andrew R. Turner
Gentra Abbey Sorem
R. Kevin Redwine
Tony W. Haynie
Bruce W. Freeman
David R. Cordell
John N. Hove
C. Raymond Patton, Jr.
Paul E. Braden
Robert J. Melgaard
P. Scott Hathaway
Lawrence A. Hall
Timothy T. Trump
Mark E. Dreyer
Nancy E. Vaughn
Gregory D. Renberg
Mark D. Berman
Katherine G. Coyle
Beverly K. Smith
Melodie Freeman-Burney
R. Richard Love, III
Robert D. James
Stephen R. Ward
Jeffrey R. Schoborg
Anne B. Sublett
J. Ryan Sacra
Jason S. Taylor
Katy Day Inhofe
Stephan A. Wangsgard
Julia Forrester-Sellers
Melinda L. Kirk
P. Bradley Bendure
Kathryn J. Kindell
Amy M. Santee
Cara M. Hair
Alissa A. Hurley
Heather Holt Bilderback
Debra R. Stockton
Shelley L. Carter
Jed W. Isbell
Conner & Winters, LLP
3700 First Place Tower
15 East Fifth
Street
Tulsa, Oklahoma 74103-4344
918-586-5711
Fax 918-586-8982
www.cwlaw.com
Writer’s Direct Number
918-586-5691
Writer’s Fax Number
918-586-8691
Writer’s E-mail Address
lmoore@cwlaw.com
Bob F. McCoy
John E. Barry
James R. Ryan
Russell H. Harbaugh, Jr.
David O. Cordell
OKLAHOMA CITY
Irwin H.
Steinhorn
John W. Funk
Jared D. Giddens
Kiran A. Phansalkar
Mitchell D. Blackburn
Mark H. Bennett
Bryan J. Wells
Laura McCasland Holbrook
John E. Gatliff II
J. Dillon Curran
William M. Lewis
L. Belynn Whatley
Peter B. Bradford
Shelia L. Darling
NORTHWEST ARKANSAS
John R. Elrod*
Greg S. Scharlau
Terri Dill Chadick
Todd P. Lewis*
P. Joshua Wisley
Charles E. Scharlau*
WASHINGTON, D.C.
G. Daniel Miller*
Henry Rose*
Erica L. Summers*
HOUSTON, TEXAS
Pamela H. Stabler*
JACKSON,
WYOMING
Randolph L. Jones, Jr.
SANTA FE, NEW MEXICO
Douglas M. Rather
Benjamin C. Conner
1879-1963
John M. Winters, Jr.
1901-1989
*Not Admitted in Oklahoma
February 21, 2005
Via Fax
Mr. Jeffrey A. Shady
Division of Corporation
Finance
Securities and Exchange Commission
450 Fifth Street,
N.W.
Washington, D.C. 20549
Re: Jameson Inns, Inc.
Amendment
No.2 to Form S-3 filed December 30, 2004
File
No. 333-119016
Dear Jeff:
This letter is
being submitted pursuant to your request. The purpose of this letter is to explain the procedures which Jameson Inns, Inc. (the “Company”) agrees to implement regarding electronic delivery of documents in the Jameson Stock Awards Program
(the “Program”). This is the issue addressed in comment no. 4 of your January 28, 2005 comment letter and in the draft of our proposed response which was submitted to you on February 10, 2005. It is proposed that each prospectus will be
amended to incorporate the terms discussed below and our response to your January 28, 2005 comment letter will be appropriately revised from the draft previously submitted to you.
When participants enroll in the Program, they will receive both the Frequent Guest Loyalty Program and Direct Stock Purchase
Plan prospectuses along with the enrollment form. If the enrollment form is written, the enrollees will receive written copies of the final prospectuses. If they enroll online, there will be links to each of the final prospectuses.
The enrollment form will require that each enrollee consent to electronic
delivery of all of the documents related to the offering, which would include any amendments or supplements to
February 21, 2005
Page 2
the final prospectuses and copies of the final prospectuses, each time shares are issued to
the participant in the Program. This consent will also provide that unless and until it is revoked, all subsequent shareholder materials and communications may be delivered electronically as well. However, the consent to delivery of subsequent
materials and communications (as opposed to the documents relating just to the offering of the shares) will be revocable and that fact will be noted on the form. Upon revocation, the participant will begin receiving written copies of these
materials. Participation in the Program will not be terminated because of a participant’s revocation of consent to electronic delivery of these materials. The participant will continue to receive shareholder materials in hard copy via U. S.
mail.
Further, participants will be sent confirmations
electronically each time shares are credited to their Program accounts for hotel stay credits or for direct stock purchases. These confirmations will comply with Rule 10b-10 of the Securities Exchange Act, as amended, and will have links to the
final prospectuses, including any amendments and supplements that might then be applicable.
We hope that this letter clarifies the revised terms of the Program as we discussed on the telephone. If you have further questions or comments, please do not hesitate to call me directly.
Yours very truly,
/s/ Lynn
Lynnwood R. Moore, Jr.
Cc: Jameson Inns, Inc.
Brinson Patrick Securities Corporation
Lehman
& Eilen LLP