SEC Company Response from Strategic Education, Inc. (STRA) (CIK 0001013934) (STRA) — Jan 5, 2009
Strategic Education, Inc. (STRA) (CIK 0001013934)
Date: Jan. 5, 2009 · CIK: 0001013934 · Accession: 0000899140-09-000020
AI Filing Summary & Sentiment
Referenced dates: November 25, 2008
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[letterhead of Strayer Education, Inc.]
VIA EDGAR
---------
January 5, 2009
Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, DC 20549
Attn: Larry Spirgel
Assistant Director
Re: Strayer Education, Inc. ("Strayer")
Form 10-K for the Fiscal Year ended December 31, 2007
Filed February 14, 2008 (the "2007 Form 10-K")
File No. 0-21039
Dear Mr. Spirgel:
I am submitting this letter as requested by Mr. John Harrington of the
staff (the "Staff") of the Securities and Exchange Commission in response to
your letter dated November 25, 2008 to Robert S. Silberman, Strayer's Chairman
of the Board and Chief Executive Officer. The comments of the Staff contained in
your letter were separately responded to on our behalf by our counsel on
December 23, 2008.
Pursuant to your letter, on behalf of Strayer, I hereby acknowledge that:
o Strayer is responsible for the adequacy and accuracy of the disclosure
in its 2007 Form 10-K;
o Staff comments or changes to disclosure in response to Staff comments
do not foreclose the Commission from taking any action with respect to
Strayer's 2007 Form 10-K; and
o Strayer may not assert Staff comments as a defense in any proceeding
initiated by the Commission or any person under the Federal securities
laws of the United States.
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Securities and Exchange Commission
January 5, 2009
Page 2
Should any member of the Staff have any questions or comments concerning
this letter, please do not hesitate to call me at (703) 247-2500.
Very truly yours,
/s/ Mark C. Brown
Mark C. Brown
Executive Vice President and Chief Financial Officer
cc: John Harrington
Paul Fischer
Robert S. Silberman
Gregory Ferenbach
Jeffrey S. Hochman
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