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SEC Company Response from ROO GROUP INC (CIK 0001076700) — Jan 27, 2005

ROO GROUP INC (CIK 0001076700)
Date: Jan. 27, 2005 · CIK: 0001076700 · Accession: 0001144204-05-002501

AI Filing Summary & Sentiment

File numbers found in text: 333-120605

Date
January 27, 2005
Author
Not clearly detected
Form
CORRESP
Company
ROO GROUP INC (CIK 0001076700)

Letter

Re: ROO Group, Inc. Registration Statement on Form SB-2 File No. 333-120605

ROO GROUP, INC. 62 WHITE ST NEW YORK, NY 10013

January 27, 2005

VIA FACSIMILE AND EDGAR United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Michael McTiernan, Esq.

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Act"), ROO Group, Inc. (the "Company") respectfully requests that the effective date of the Registration Statement referred to above be accelerated so that it will become effective at 4:00 pm, Eastern Time, on Monday, January 31, 2005, or as soon thereafter as possible.

We hereby acknowledge the following:

o 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;

o 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

o the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States

ROO GROUP, INC.

By: /s/ Robert Petty -------------------------------- Name: Robert Petty Title: Chief Executive Officer

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                                 ROO GROUP, INC.
                                   62 WHITE ST
                               NEW YORK, NY 10013

                                                              January 27, 2005

VIA FACSIMILE AND EDGAR
United States Securities
 and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention:  Michael McTiernan, Esq.

         Re:      ROO Group, Inc.
                  Registration Statement on Form SB-2
                  File No. 333-120605

Ladies and Gentlemen:

         Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Act"), ROO Group, Inc. (the "Company")
respectfully requests that the effective date of the Registration Statement
referred to above be accelerated so that it will become effective at 4:00 pm,
Eastern Time, on Monday, January 31, 2005, or as soon thereafter as possible.

         We hereby acknowledge the following:

         o        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;

         o        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

         o        the Company may not assert this action as a defense in any
                  proceeding initiated by the Commission or any person under the
                  federal securities laws of the United States

                                        ROO GROUP, INC.

                                        By:  /s/ Robert Petty
                                             --------------------------------
                                             Name:  Robert Petty
                                             Title:   Chief Executive Officer

</TEXT>
</DOCUMENT>