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SEC Company Response from GeoEye, Inc. (CIK 0001040570) — Nov 29, 2004

GeoEye, Inc. (CIK 0001040570)
Date: Nov. 29, 2004 · CIK: 0001040570 · Accession: 0000950133-04-004453

AI Filing Summary & Sentiment

Referenced dates: October 26, 2004

Date
Nov. 29, 2004
Author
William P. O’Neill
Form
CORRESP
Company
GeoEye, Inc. (CIK 0001040570)

Letter

VIA EDGAR CORRESPONDENCE Division of Corporation Finance Securities and Exchange Commission Orbimage Inc. Form 10 Filed September 13, 2004 File No. 050933

Dear Mr. Spirgel:

We are writing on behalf of our client, ORBIMAGE Inc. (the “Company”). We make reference to the Staff’s comment letter, dated October 26, 2004, relating to the above-referenced filing of the Company on Form 10. As I discussed in a telephone conversation with John McIntyre of the Staff this afternoon, we hereby request that you treat as timely the Company’s response to the Staff’s comment letter if the Company responds to such letter on or before December 1, 2004.

The Company has requested extra time to enable its former independent accounting firm, PricewaterhouseCoopers, review the Company’s response, including its Form 10/A that the Company will be filing with its response. In requesting this extra time, we acknowledge and appreciate the advice of the Staff that a review by PricewaterhouseCoopers is not required in these circumstances. The Company has discussed this view with PricewaterhouseCoopers and has determined that it would in the Company’s best interests to give its former accounting firm the opportunity to complete its review of the Company’s response and the Form 10/A as requested by the firm. The Company intends to seek the consent of PricewaterhouseCoopers for the inclusion of the firm’s report on the Company’s financial statements for the year ended December 31, 2001 in future filings.

If you have any questions please do not hesitate to call me at (202) 637 – 2275, or the Company’s General Counsel, William Warren, at (703) 480 – 5672.

Respectfully yours,
William P. O’Neill

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CORRESP
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corresp

    555 Eleventh Street, N.W., Suite 1000

    Washington, D.C. 20004-1304

    Tel: (202) 637-2200 Fax: (202) 637-2201

    www.lw.com

    FIRM / AFFILIATE OFFICES

    Boston

    New Jersey

    Brussels

    New York

    Chicago

    Northern Virginia

    Frankfurt

    Orange County

    Hamburg

    Paris

    Hong Kong

    San Diego

    London

    San Francisco

    Los Angeles

    Silicon Valley

    Milan

    Singapore

    Moscow

    Tokyo

    Washington, D.C.

November 29, 2004

VIA EDGAR CORRESPONDENCE

Larry Spirgel

Assistant Director

Division of Corporation Finance

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549-0305

    RE:

    Orbimage Inc.

Form 10

Filed September 13, 2004

File No. 050933

Dear Mr. Spirgel:

     We are writing on behalf of our client, ORBIMAGE Inc. (the “Company”). We
make reference to the Staff’s comment letter, dated October 26, 2004, relating
to the above-referenced filing of the Company on Form 10. As I discussed in a
telephone conversation with John McIntyre of the Staff this afternoon, we
hereby request that you treat as timely the Company’s response to the Staff’s
comment letter if the Company responds to such letter on or before December 1,
2004.

     The
Company has requested extra time to enable its former independent
accounting firm,
PricewaterhouseCoopers, review the Company’s response, including its Form 10/A
that the Company will be filing with its response. In requesting this extra
time, we acknowledge and appreciate the advice of the Staff that a review by
PricewaterhouseCoopers is not required in these circumstances. The Company
has discussed this view with PricewaterhouseCoopers and has determined that it
would in the Company’s best interests to give its former accounting firm the
opportunity to complete its review of the Company’s response and the Form 10/A
as requested by the firm. The Company intends to seek the consent of
PricewaterhouseCoopers for the inclusion of the firm’s report on the Company’s
financial statements for the year ended December 31, 2001 in future filings.

     If you have any questions please do not hesitate to call me at (202) 637 –
2275, or the Company’s General Counsel, William Warren, at (703) 480 – 5672.

Respectfully yours,

William P. O’Neill

of LATHAM & WATKINS LLP

    cc:

    John McIntyre

Derek Swanson

William L. Warren, ORBIMAGE Inc.