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SEC Company Response from SECURE COMPUTING CORP (CIK 0001001916) — Dec 7, 2005

SECURE COMPUTING CORP (CIK 0001001916)
Date: Dec. 7, 2005 · CIK: 0001001916 · Accession: 0001193125-05-238288

AI Filing Summary & Sentiment

File numbers found in text: 333-128410

Date
December 7, 2005
Author
/s/ Mary Budge
Form
CORRESP
Company
SECURE COMPUTING CORP (CIK 0001001916)

Letter

Re: Secure Computing Corporation Registration Statement

SEC Letter

VIA EDGAR and FACSIMILE

(202) 773-9210

SECURITIES AND EXCHANGE COMMISSION

100 F Street, N.E.

Washington, D.C. 20549

ATTENTION: Mr. Daniel Lee

on Form S-4 (No. 333-128410)

Ladies and Gentlemen:

Secure Computing Corporation (the “Company”), as required by Rule 461(a) under the Securities Act of 1933, as amended, hereby requests that the effective date for the Registration Statement referred to above be accelerated to 5:00 p.m. Eastern Time on Wednesday, December 7, 2005, or as soon thereafter as practicable.

In addition, the Company acknowledges that (i) should the Securities and Exchange Commission (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; (ii) 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 (iii) the Company may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely
/s/ Mary Budge

Show Raw Text
CORRESP
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SEC Letter

 VIA EDGAR and FACSIMILE

 (202) 773-9210

 SECURITIES AND EXCHANGE COMMISSION

 100 F Street, N.E.

 Washington, D.C. 20549

 ATTENTION:
Mr. Daniel Lee

Re:
Secure Computing Corporation Registration Statement

on Form S-4 (No. 333-128410)

 Ladies and Gentlemen:

 Secure Computing Corporation (the “Company”), as required by Rule 461(a) under the Securities Act of 1933, as amended, hereby requests that the
effective date for the Registration Statement referred to above be accelerated to 5:00 p.m. Eastern Time on Wednesday, December 7, 2005, or as soon thereafter as practicable.

 In addition, the Company acknowledges that (i) should the Securities and Exchange Commission (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; (ii) 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 (iii) the Company may not assert the staff
comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely

 /s/ Mary Budge

 Mary Budge

 Senior Vice President, Secretary and General

 Counsel

cc:
Tim Steinkopf

Kyle Guse