SEC Company Response from OCEAN WEST HOLDING CORP (CIK 0001104538) — Nov 23, 2005
OCEAN WEST HOLDING CORP (CIK 0001104538)
Date: Nov. 23, 2005 · CIK: 0001104538 · Accession: 0001144204-05-037544
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File numbers found in text: 000-49971
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<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
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ELLIOT H. LUTZKER
885 Third Avenue
Suite 2800
New York, NY 10022
Main (212) 451-2900
Fax (212) 451-2999
elutzker@rc.com
Direct (212) 451-2906
Also admitted in Florida
November 23, 2005
Via EDGAR and Facsimile
Mr. Timothy Geishecker
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Ocean West Holding Corporation
Preliminary Information Statement filed on November 3, 2005
File No. 000-49971
Dear Mr. Geishecker:
In connection with the above-referenced matter and on behalf of our client
Ocean West Holding Corporation (the "Company"), this is in response to the
Staff's letter issued on November 22, 2005. We will address your comments in the
order in which they appear in your letter. Wherever reference is made to the
amended Information Statement, it refers to the amended Schedule 14C which we
advised you will be filed shortly under a separate cover letter.
General
1. The Registrant will register the Shares of Ocean West Enterprises
under the Securities Act of 1933.
2. This comment has been complied with.
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Ms. Timothy Geishecker
November 23, 2005
Page 2
3. This comment has been complied with. The entire board of directors
is acting as nominating committee.
4. This comment will be complied with under separate filings.
Management's "Tandy" response has been provided in a separate letter filed
on EDGAR, a copy of which is attached hereto.
The Company believes that upon the filing of the revised Information
Statement together with the revised Form 8-K/A it will have complied with all of
the Staff's Comments. The Quarterly Report on Form 10-QSB for September 30, 2005
filed on November 21, 2005 includes the discontinued operations of Ocean West
Enterprises in accordance with Comment No. 4. The June 30, 2005 Form 10-QSB, as
well as the March and December Form 10-QSB's are not required to be mailed as
exhibits and have been deleted from the Exhibit Index on page 20 of the
Information Statement. Therefore, the Company believes it will be in compliance
with all outstanding comments and able to mail the Information Statement once
the above filings are made.
Thank you for your consideration.
Very truly yours,
ROBINSON & COLE LLP
/s/ Elliot H. Lutzker
---------------------
Elliot H. Lutzker
cc: Darryl Cohen
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