SEC Company Response from ORION ACQUISITION CORP II (CIK 0001011835) — May 12, 2005
ORION ACQUISITION CORP II (CIK 0001011835)
Date: May 12, 2005 · CIK: 0001011835 · Accession: 0001193125-05-105760
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File numbers found in text: 333-122431
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CORRESP 1 filename1.htm Acceleration Letter Orion Acquisition Corp. II 501 Second Street, Suite 211 San Francisco, California 94107 May 12, 2005 VIA EDGAR TRANSMISSION & FACSIMILE Mr. John Reynolds Assistant Director, Office of Emerging Growth Companies Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549 Mail Stop: 0511 Re: Registration Statement on Form SB-2 (Registration No. 333-122431), as amended, of Orion Acquisition Corp. II Ladies and Gentlemen: Orion Acquisition Corp. II, a Delaware corporation (the “Company”), hereby respectfully requests acceleration pursuant to Rule 461 under the Securities Act of 1933, as amended, of the Registration Statement on Form SB-2 (Registration No. 333-122431), as amended, of the Company (the “Registration Statement”), so that the Registration Statement will be declared effective by the Securities and Exchange Commission (the “Commission”) at 4:30 p.m. eastern time on May 16, 2005, or as soon as practicable thereafter. In addition, the Company respectfully requests that a copy of the written order from the Commission verifying the effective time and date of the Registration Statement be sent to the Company’s counsel, Latham & Watkins LLP, Attention: Bradley A. Bugdanowitz, by facsimile to (415) 395-8095. Very truly yours, ORION ACQUISITION CORP. II By: /s/ C. Patrick Machado Name: C. Patrick Machado Title: Senior Vice President and Chief Financial Officer cc: Bradley A. Bugdanowitz, Esq. Latham & Watkins LLP