SEC Comment Letter for BGC Group, Inc. (BGC) (CIK 0001094831) (BGC) — Aug 29, 2006
BGC Group, Inc. (BGC) (CIK 0001094831)
Date: Aug. 29, 2006 · CIK: 0001094831 · Accession: 0000000000-06-041773
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Mail Stop 4561
August 29, 2006
VIA U.S. MAIL AND FAX (212) 829-4708
Mr. Howard W. Lutnick
Chief Executive Officer
eSpeed, Inc.
110 East 59th
New York, NY 10022
Re: eSpeed, Inc.
Form 10-K for the year ended December 31, 2005
Filed March 15, 2006
File No. 0-28191
Dear Mr. Lutnick:
We have reviewed your response letter filed July 14, 2006 and have the following
additional comment. Please be as detailed as necessary in your explanation. In our
comment, we may ask you to provide us with information so we may better understand
your disclosure. After reviewing this information, we may or may not raise additional
comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. Howard W . Lutnick
eSpeed, Inc.
August 29, 2006
Page 2
Form 10-K for the year ended December 31, 2005
Note 9. Commitments and Contingencies, page 73
1. We have reviewed your response to commen t #2. In your disclosure of the action
commenced by Trading Technologies Internat ional, Inc., please clarify whether
there is at least a reasonable possibility that a loss may have been incurred. If so,
please revise to also give an estimate of the possible loss or ra nge of loss or state
that such an estimate cannot be made. Refer to paragraph 10 of SFAS 5 and SAB
Topic 5Y. Please show us how you will revise your disclosure in response to this
comment.
* * * *
A s appropriate, please respond to this comm ent within 10 business days or tell us
when you will provide us with a response. Please furnish a cover letter with your response that keys your responses to our comments and provides any requested
information. Detailed cover le tters greatly facilitate our re view. Please understand that
we may have additional comments after reviewing your response to our comment.
If you have any questions, you may contact Eric McPhee at (202) 551-3693 or me
at (202) 551-3431.
Sincerely,
Josh Forgione
Assistant Chief Accountant