SEC Company Response from CSG SYSTEMS INTERNATIONAL INC (CSGS) (CIK 0001005757) (CSGS) — Jul 29, 2005
CSG SYSTEMS INTERNATIONAL INC (CSGS) (CIK 0001005757)
Date: July 29, 2005 · CIK: 0001005757 · Accession: 0001193125-05-152527
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File numbers found in text: 333-117427
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CORRESP 1 filename1.htm Letter to the Securities and Exchange Commission DAVIS POLK & WARDWELL 450 LEXINGTON AVENUE NEW YORK, NEW YORK 10017 212-450-4000 FAX: 212-450-3800 July 29, 2005 Re: CSG Systems International, Inc. Registration Statement on Form S-3 Post-Effective Amendment No. 4 Registration No. 333-117427 Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Dear Sir/Madam: On behalf of CSG Systems International, Inc. (the “Company”) and pursuant to the provisions of the Securities Act of 1933, as amended (the “Securities Act”), and Rule 101(a) of Regulation S-T, we are submitting for filing Post-Effective Amendment No. 4 (the “Post-Effective Amendment No. 4”) to the Registration Statement on Form S-3 (Registration No. 333-117427) (as amended, the “Registration Statement”) in electronic format relating to the Company’s 2.50% Senior Subordinated Convertible Contingent Debt SecuritiesSM (CODESSM) due 2024 and the shares of common stock issuable upon conversion of the CODES. The primary reason for this filing is to update the selling securityholder information at the request of the selling securityholders. This letter confirms that an oral request for acceleration of the effective date of the Post-Effective Amendment No. 4 will be made in accordance with Rule 461 of the Securities Act. The Company is aware of its obligations under the Securities Act. If you have any questions or comments relating to this submission, please call me at (212) 450-4536. Very truly yours, /s/ Hugh McCullough Hugh McCullough Cc: Joseph T. Ruble General Counsel and Corporate Secretary CSG Systems International, Inc.