SEC Company Response from Orange 21 Inc. (CIK 0000932372) — Dec 13, 2004
Orange 21 Inc. (CIK 0000932372)
Date: Dec. 13, 2004 · CIK: 0000932372 · Accession: 0001047469-04-036926
AI Filing Summary & Sentiment
File numbers found in text: 333-119024
Referenced dates: October 14, 2004
Letter
VIA EDGAR AND FACSIMILE Division of Corporation Finance Attention: Eduardo Aleman, Staff Attorney Re:Orange 21 Inc. Registration Statements on Form S-1 and Form 8-A File No. 333-119024
Dear Mr. Aleman,
Pursuant to Rule 461 promulgated under the Securities Act of 1933, Orange 21 Inc. hereby requests that the effective date of its Registration Statements on Form S-1 (File No. 333-119024) and Form 8-A (collectively, the "Registration Statements") be accelerated so that the same will become effective at 5:30 p.m., Eastern time, on December 13, 2004 or as soon thereafter as practicable as the U.S. Securities and Exchange Commission (the "Commission") may determine.
Pursuant to your letter dated October 14, 2004 to Spy Optic, Inc., Orange 21 acknowledges the following in connection with this acceleration request:
•should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
•the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
•the company may 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.
Please confirm that the Registration Statements have been declared effective by telephoning Christopher M. Forrester at (858) 342-4705.
Thank you for your attention to this matter.
Very
truly yours,
Orange
21 Inc.
Show Raw Text
CORRESP 1 filename1.htm ORANGE 21 INC. 2070 Las Palmas Drive Carlsbad, California 92009 (760) 804-8420 December 13, 2004 VIA EDGAR AND FACSIMILE Division of Corporation Finance U.S. Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549-0306 Attention: Eduardo Aleman, Staff Attorney Re:Orange 21 Inc. Registration Statements on Form S-1 and Form 8-A File No. 333-119024 Dear Mr. Aleman, Pursuant to Rule 461 promulgated under the Securities Act of 1933, Orange 21 Inc. hereby requests that the effective date of its Registration Statements on Form S-1 (File No. 333-119024) and Form 8-A (collectively, the "Registration Statements") be accelerated so that the same will become effective at 5:30 p.m., Eastern time, on December 13, 2004 or as soon thereafter as practicable as the U.S. Securities and Exchange Commission (the "Commission") may determine. Pursuant to your letter dated October 14, 2004 to Spy Optic, Inc., Orange 21 acknowledges the following in connection with this acceleration request: •should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; •the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and •the company may 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. Please confirm that the Registration Statements have been declared effective by telephoning Christopher M. Forrester at (858) 342-4705. Thank you for your attention to this matter. Very truly yours, Orange 21 Inc. By: /s/ BARRY BUCHHOLTZ Name: Barry Buchholtz Title: Chief Executive Officer