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SEC Company Response from GENERAL GEOPHYSICS CO (CIK 0001037962) — Sep 21, 2005

GENERAL GEOPHYSICS CO (CIK 0001037962)
Date: Sept. 21, 2005 · CIK: 0001037962 · Accession: 0000950123-05-011367

AI Filing Summary & Sentiment

File numbers found in text: 333-126556

Date
September 21, 2005
Author
Not clearly detected
Form
CORRESP
Company
GENERAL GEOPHYSICS CO (CIK 0001037962)

Letter

Division of Corporation Finance Securities and Exchange Commission Re: General Geophysics Company Registration Statement on Forms F-4 and S-4 (SEC File No. 333-126556)

Dear Mr. Wynn:

The Company hereby respectfully requests that the Registration Statement, as amended, be declared effective at 5:00 p.m. September 23, 2005 or as soon thereafter as practicable.

The Company hereby acknowledges that:

•

should 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;

•

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

•

the Company may not assert 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.

Very truly yours,
Compagnie Générale de Géophysique (General Geophysics Company)

Show Raw Text
CORRESP
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filename1.htm

LETTER TO JASON WYNN

[CGG Letterhead]

September 21, 2005

Mr. Jason Wynn

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    General Geophysics Company

Registration Statement on Forms F-4 and S-4

(SEC File No. 333-126556)

Dear Mr. Wynn:

The Company hereby respectfully requests that the Registration Statement, as amended, be declared
effective at 5:00 p.m. September 23, 2005 or as soon thereafter as practicable.

The Company hereby acknowledges that:

    •

    should 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;

    •

    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

    •

    the Company may not assert 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.

Very truly yours,

Compagnie Générale de Géophysique (General Geophysics Company)

By: /s/ Michel Ponthus

Michel Ponthus

Senior Executive Vice President

Legal Affairs and Human Resources

and Secretary General

    cc:

    H. Roger Schwall

Assistant Director