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SEC Company Response from FIRSTPLUS FINANCIAL GROUP INC (CIK 0001000368) — Nov 21, 2005

FIRSTPLUS FINANCIAL GROUP INC (CIK 0001000368)
Date: Nov. 21, 2005 · CIK: 0001000368 · Accession: 0000899078-05-000946

AI Filing Summary & Sentiment

Referenced dates: November 18, 2005

Date
November 21, 2005
Author
/s/ Douglas M. Berman
Form
CORRESP
Company
FIRSTPLUS FINANCIAL GROUP INC (CIK 0001000368)

Letter

Douglas M. Berman

(214) 855-4149

dberman@jenkens.com

Jenkens & Gilchrist

A PROFESSIONAL CORPORATION

1445 ROSS AVENUE

SUITE 3200

DALLAS, TEXAS 75202

(214) 855-4500

FACSIMILE (214) 855-4300

www.jenkens.com

AUSTIN, TEXAS (512) 499-3800

CHICAGO, ILLINOIS (312) 425-3900

HOUSTON, TEXAS (713) 951-3300

LOS ANGELES, CALIFORNIA (310) 820-8800

SAN ANTONIO, TEXAS (210) 246-5000

WASHINGTON, D.C. (202) 326-1500

November 21, 2005

VIA EDGAR FILING

Securities and Exchange Commission

100 F Street, N.E.

Washington D.C. 20549-3628

Attention:

Daniel F. Duchovny, Attorney-Advisor

Office of Mergers and Acquisitions

Re:

FIRSTPLUS Financial Group, Inc.

Response to November 1, 2005 comments filed November 14, 2005

File No. 1-13753

Ladies and Gentlemen:

On behalf of FIRSTPLUS Financial Group, Inc. (the “Company”), we are transmitting via EDGAR to the Securities and Exchange Commission (the “Commission”) the following responses of the Company to the comments of the Commission’s staff (the “Staff”) as set forth in the letter of Daniel F. Duchovny, Attorney-Advisor, Office of Mergers and Acquisitions, dated November 18, 2005.

The responses herein are based on information provided to this firm by the Company. For your convenience, we have repeated each comment prior to the response.

1. We note your responses to 1, 2 and 4 in our November 1st comment letter. We also note that you have removed from your web site the letter which was the basis for some of our comments. Please confirm that you will avoid making the statements cited in these comments in any future shareholder communications, or provide us additional factual support for these statements.

In response to the Staff’s comment, the Company hereby informs the Staff that it will avoid making the statements cited in the above referenced comments in any future shareholder communications, or provide the Commission additional factual support for these statements.

Closing Comments

The Company acknowledges the Commission’s comments. These general comments have been noted and/or complied with as applicable.

Please do not hesitate to call the undersigned at the number referenced above if you have any questions or comments regarding the foregoing or if we can be of service in facilitating your review of this filing.

Sincerely,
/s/ Douglas M. Berman

Show Raw Text
CORRESP
1
filename1.htm

Douglas M. Berman

(214) 855-4149

dberman@jenkens.com

            Jenkens & Gilchrist

A PROFESSIONAL CORPORATION

1445 ROSS AVENUE

SUITE 3200

DALLAS, TEXAS  75202

(214) 855-4500

FACSIMILE (214) 855-4300

www.jenkens.com

AUSTIN, TEXAS
 (512) 499-3800

CHICAGO, ILLINOIS
 (312) 425-3900

HOUSTON, TEXAS
 (713) 951-3300

LOS ANGELES, CALIFORNIA
 (310)
820-8800

SAN ANTONIO, TEXAS
 (210) 246-5000

WASHINGTON, D.C.
 (202) 326-1500

            November 21, 2005

VIA EDGAR FILING

Securities and Exchange Commission

100 F Street, N.E.

Washington D.C. 20549-3628

            Attention:

            Daniel F. Duchovny, Attorney-Advisor

            Office of Mergers and Acquisitions

            Re:

            FIRSTPLUS Financial Group, Inc.

            Response to November 1, 2005 comments filed November 14, 2005

            File No. 1-13753

Ladies and Gentlemen:

On behalf of FIRSTPLUS Financial Group, Inc. (the “Company”), we are transmitting via EDGAR to the Securities and Exchange Commission (the “Commission”) the following responses of the Company to the comments of the Commission’s staff (the “Staff”) as set forth in the letter of Daniel F. Duchovny, Attorney-Advisor, Office of Mergers and Acquisitions, dated November 18, 2005.

The responses herein are based on information provided to this firm by the Company.  For your convenience, we have repeated each comment prior to the response.

1.              We note your responses to 1, 2 and 4 in  our November 1st comment letter.  We also note that you have removed from your web site the letter which was the basis for some of our comments.  Please confirm that you will avoid making the statements cited in these comments in any future shareholder communications, or provide us additional factual support for these statements.

In response to the Staff’s comment, the Company hereby informs the Staff that it will avoid making the statements cited in the above referenced comments in any future shareholder communications, or provide the Commission additional factual support for these statements.

Closing Comments

The Company acknowledges the Commission’s comments.  These general comments have been noted and/or complied with as applicable.

Please do not hesitate to call the undersigned at the number referenced above if you have any questions or comments regarding the foregoing or if we can be of service in facilitating your review of this filing.

            Sincerely,

            /s/ Douglas M. Berman

            Douglas M. Berman

Attachments

            cc:

            Jack (J.D.) Draper

            Andrew E. Jillson, Esq.

Joseph C. Edwards, Esq.

Mark D. Wigder, Esq.

            James W. Puzey, Esq.