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SEC Company Response from RICEX CO (CIK 0001061881) — Jul 19, 2005

RICEX CO (CIK 0001061881)
Date: July 19, 2005 · CIK: 0001061881 · Accession: 0000897069-05-001756

AI Filing Summary & Sentiment

Referenced dates: June 13, 2005, June 21, 2005

Date
July 18, 2005
Author
Not clearly detected
Form
CORRESP
Company
RICEX CO (CIK 0001061881)

Letter

VIA EDGAR – CORRESPONDENCE FILING Securities and Exchange Commission Judiciary Plaza 450 Fifth Street, N.W., Stop 4-5 Washington, D.C. 20549 Attn: Jonathan Duersch Form 10-QSB for Fiscal Quarter Ended March 31, 2005, Filed May 16, 2005 SEC File No. 0-24285

Re: The RiceX Company (the “Company”) Form 10-KSB for Fiscal Year Ended December 31, 2004, Filed March 30, 2005

Dear Mr. Duersch:

In connection with our response letter dated June 21, 2005 (the “Response”) to your letter dated June 13, 2005 requesting that we provide the Securities and Exchange Commission (the “Commission”) with certain additional information regarding the matters discussed in our Annual Report on Form 10-KSB for the fiscal year ended December 31, 2004, filed with the Commission on March 31, 2005, we hereby supplement our Response as follows and acknowledge that:

• 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 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 contact directly our attorney, Deepak Nanda, Esq., at (310) 975-7912, with any questions or comments regarding this matter. Mr. Nanda’s facsimile number is (310) 557-8475.

Thank you for your consideration.

THE RICEX COMPANY

By: /s/ Todd C. Crow

Todd C. Crow

Chief Financial Officer

Show Raw Text
CORRESP
1
filename1.htm

[THE RICEX COMPANY
LETTERHEAD]

July 18, 2005

VIA EDGAR –
CORRESPONDENCE FILING

Securities and Exchange
Commission
Judiciary Plaza
450 Fifth Street, N.W., Stop 4-5
Washington, D.C. 20549
Attn:
Jonathan Duersch

Re:
The
RiceX Company (the “Company”)
 Form 10-KSB for Fiscal Year Ended December 31, 2004, Filed March 30, 2005

Form 10-QSB for Fiscal Quarter Ended March 31, 2005, Filed May 16, 2005
 SEC File No.
0-24285

Dear Mr. Duersch:

        In
connection with our response letter dated June 21, 2005 (the “Response”) to your
letter dated June 13, 2005 requesting that we provide the Securities and Exchange
Commission (the “Commission”) with certain additional information regarding the
matters discussed in our Annual Report on Form 10-KSB for the fiscal year ended
December 31, 2004, filed with the Commission on March 31, 2005, we hereby supplement our
Response as follows and acknowledge that:

•
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 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
contact directly our attorney, Deepak Nanda, Esq., at (310) 975-7912, with any questions or
comments regarding this matter. Mr. Nanda’s facsimile number is (310) 557-8475.

        Thank
you for your consideration.

     THE RICEX COMPANY

     By: /s/ Todd C. Crow

           Todd C. Crow

           Chief Financial Officer