SEC Comment Letter for FIRSTPLUS FINANCIAL GROUP INC (CIK 0001000368) — Oct 18, 2005
FIRSTPLUS FINANCIAL GROUP INC (CIK 0001000368)
Date: Oct. 18, 2005 · CIK: 0001000368 · Accession: 0000000000-05-053194
AI Filing Summary & Sentiment
Letter
October 18, 2005 Danford L. Martin The FPFX Shareholder Value Committee 7 Egret Lane Aliso Viejo, CA 92656
Re: Firstplus Financial Group, Inc. Revised Preliminary Proxy Statement on Schedule 14A Response to comments filed October 14, 2005 by The FPFX Shareholder Value Committee File No. 1-13753
Dear Mr. Martin:
We have reviewed your filing and have the following comments. 1. It has come to our attention that a member of The FPFX Shareholder Value Committee, Mr. Danford Martin, has sent messages via electronic mail to the security holders of Firstplus Financial Group under the name of "FPFX Steering Committee," without filing the messages as definitive additional soliciting materials. These communications appear to be soliciting materials relating to the current proxy solicitation and should have been filed on the date of first use as required by Rule 14a-12. File all such materials as soon as possible and provide us your analysis regarding your compliance with this rule. We may have further comments. 2. In connection with the FPFX Steering Committee, please tell us who are its members, the number of shares held by each member, what activities it is conducting, and the committee`s goals or purposes. In addition, please provide us your analysis why the Steering Committee has not filed a Schedule 13D as a group and why the Steering Committee is not a part of your group. Please contact the undersigned at (202) 551-3619 for assistance with respect to the foregoing comments and your proxy materials.
Sincerely,
Daniel F. Duchovny
Attorney-Advisor
Office of Mergers and Acquisitions
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October 18, 2005
Danford L. Martin
The FPFX Shareholder Value Committee
7 Egret Lane
Aliso Viejo, CA 92656
Re: Firstplus Financial Group, Inc.
Revised Preliminary Proxy Statement on Schedule 14A
Response to comments filed October 14, 2005 by The FPFX
Shareholder Value Committee
File No. 1-13753
Dear Mr. Martin:
We have reviewed your filing and have the following comments.
1. It has come to our attention that a member of The FPFX
Shareholder
Value Committee, Mr. Danford Martin, has sent messages via
electronic
mail to the security holders of Firstplus Financial Group under
the
name of "FPFX Steering Committee," without filing the messages as
definitive additional soliciting materials. These communications
appear to be soliciting materials relating to the current proxy
solicitation and should have been filed on the date of first use
as
required by Rule 14a-12. File all such materials as soon as
possible
and provide us your analysis regarding your compliance with this
rule. We may have further comments.
2. In connection with the FPFX Steering Committee, please tell us
who
are its members, the number of shares held by each member, what
activities it is conducting, and the committee`s goals or
purposes.
In addition, please provide us your analysis why the Steering
Committee has not filed a Schedule 13D as a group and why the
Steering Committee is not a part of your group.
Please contact the undersigned at (202) 551-3619 for
assistance
with respect to the foregoing comments and your proxy materials.
Sincerely,
Daniel F. Duchovny
Attorney-Advisor
Office of Mergers and Acquisitions
cc: Nathan Jenkins, Esq. (via facsimile: (775) 829-0511)
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Danford L. Martin
The FPFX Shareholder Value Committee
October 19, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3628
DIVISION OF
CORPORATION FINANCE
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