SEC Comment Letter for GeoEye, Inc. (CIK 0001040570) — Jan 10, 2005
GeoEye, Inc. (CIK 0001040570)
Date: Jan. 10, 2005 · CIK: 0001040570 · Accession: 0000000000-05-001662
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Mail Stop 0407
January 10, 2005
Via U.S. Mail and Fax (703) 480-7544
Matthew M. O`Connell
President and Chief Executive Officer
Orbimage Inc.
21700 Atlantic Boulevard
Dulles, Virginia 20166
RE: Orbimage Inc.
Form 10 Amendment No. 2
Filed January 4, 2005
File No. 0-50933
Dear Mr. O`Connell:
We have reviewed your Amendment No. 2 to your Form 10 and
have
the following comments. Please amend the registration statement
in
response to these comments within 15 days from the date of this
letter. We welcome any questions you may have about our comments
or
on any other aspect of our review. Feel free to call us at the
telephone numbers listed at the end of this letter.
Form 10
General
1. We note you have not yet complied with Item 601(b)(10) of
Regulation S-K regarding material contracts between Orbimage and
the
U.S. Government. We expect to have additional comments upon the
filing of those contracts.
Item 1. Business
Company History; Relationship with Orbital Sciences, page 2
2. Please revise your Form 10 to disclose the aggregate amounts
paid
and payable to Orbital Sciences.
Management`s Discussion and Analysis
Capital Structure and Resources, page 28
3. Please revise your Form 10 to include the information provided
in
your response to our prior comment no. 11, with respect to the
funding of approximately $45 million of future capital
expenditures
from cash flow generated from Orbimage`s existing business.
* * * *
Please amend your registration statement in response to
these
comments within 15 days from the date of this letter. You may
wish
to provide us with marked copies of the amendment to expedite our
review. Please furnish a cover letter with your amendment that
keys
your responses to our comments and provides any requested
supplemental information. File the cover letter on EDGAR as
correspondence. Detailed cover letters greatly facilitate our
review. Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.
You may contact Terry French, Accountant Branch Chief at
(202)
942-1998 if you have questions regarding comments on the financial
statements and related matters. Please contact Derek Swanson,
Staff
Attorney, at (202) 824-5526, Robert Bartelmes, Senior Financial
Analyst, at (202) 942-2867, or me at (202) 942-1990 with any other
questions.
Sincerely,
Larry Spirgel
Assistant Director
cc: William L. Warren
Vice President, General Counsel, and Secretary
Orbimage Inc.
Via Fax (703) 480-7544
William P. O`Neill
Latham & Watkins, LLP
Via Fax (202) 637-2201
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Orbimage, Inc.
January 10, 2005
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