SEC Company Response from COSINE COMMUNICATIONS INC (CIK 0001060824) — Oct 21, 2005

COSINE COMMUNICATIONS INC (CIK 0001060824)
Date: Oct. 21, 2005 · CIK: 0001060824 · Accession: 0001144204-05-032301

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AI Filing Summary & Sentiment

Referenced dates: October 18, 2005

Date

Oct. 21, 2005

Author

/s/TERRY

Form

CORRESP

Company

COSINE COMMUNICATIONS INC (CIK 0001060824)

Letter

VIA EDGAR AND OVERNIGHT DELIVERY United States Securities and Exchange Commission Division of Corporate Finance Attention: Mark P. Shuman Re: CoSine Communications, Inc. Preliminary Proxy Statement on Schedule 14A filed October 6, File No. 0-30715

Dear Mr. Shuman:

On behalf of CoSine Communications, Inc. (the "Company"), I make the following acknowledgments in response to the request from the Staff of the Securities and Exchange Commission (the "Commission") received by letter dated October 18, 2005, relating to the Company's Preliminary Proxy Statement on Schedule 14A (File No. 0-30715) filed with the Commission on October 6, 2005 (the "Filing"):

The Company is responsible for the adequacy and accuracy of the disclosure in the Filing;

Staff comments or changes to disclosure in response to Staff comments in the Filing reviewed by the Staff do not foreclose the Commission from taking any action with respect to the Filing: and

The Company 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.

Please direct your questions or comments regarding the Company's above acknowledgments to the undersigned at (408) 236-7518. Thank you for your assistance.

Sincerely,
/s/TERRY
GIBSON

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CORRESP
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filename1.htm

      CoSine
        Communications, Inc.

      560
        South Winchester Blvd., Suite 500

      San
        Jose, California 95128

      October
        21, 2005

      VIA
        EDGAR AND OVERNIGHT DELIVERY

      United
        States Securities and Exchange Commission

      Division
        of Corporate Finance

      100
        F
        Street, NE

      Washington,
        D.C. 20549

      Attention: Mark
        P.
        Shuman

      Sara
        Kalin

                Re:

                CoSine
                  Communications, Inc.

                Preliminary
                  Proxy Statement on Schedule 14A filed October 6,
                  2005

                File
                  No. 0-30715

      Dear
        Mr.
        Shuman:

      On
        behalf
        of CoSine Communications, Inc. (the "Company"), I make the following
        acknowledgments in response to the request from the Staff of the Securities
        and
        Exchange Commission (the "Commission") received by letter dated October 18,
        2005, relating to the Company's Preliminary Proxy Statement on Schedule 14A
        (File No. 0-30715) filed with the Commission on October 6, 2005 (the
        "Filing"):

                1.

                The
                  Company is responsible for the adequacy and accuracy of the disclosure
                  in
                  the Filing;

                2.

                Staff
                  comments or changes to disclosure in response to Staff comments
                  in the
                  Filing reviewed by the Staff do not foreclose the Commission from
                  taking
                  any action with respect to the Filing:
                  and

                3.

                The
                  Company 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.

      Please
        direct your questions or comments regarding the Company's above acknowledgments
        to the undersigned at (408) 236-7518. Thank you for your
        assistance.

      Sincerely,

      /s/TERRY
        GIBSON

      Terry
        Gibson,

      Chief
        Executive Officer

SecProbe.io