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SEC Company Response from OCCAM NETWORKS — Dec 22, 2005

OCCAM NETWORKS INC/DE (CIK 0001108185)
Date: Dec. 22, 2005 · CIK: 0001108185 · Accession: 0001193125-05-247676

AI Filing Summary & Sentiment

File numbers found in text: 333-125061

Date
December 22, 2005
Author
By
Form
CORRESP
Company
OCCAM NETWORKS INC/DE (CIK 0001108185)

Letter

Acceleration Request

OCCAM NETWORKS, INC.

77 Robin Hill Road

Santa Barbara, CA 93117

Tel. (805) 692-2900, Fax (805) 692-2999

December 22, 2005

VIA EDGAR

Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549

Re: Occam Networks, Inc.

Registration Statement on Form S-1 (File: 333-125061) – Rights Offering

Ladies and Gentlemen:

We hereby request acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (the “Registration Statement”) for Occam Networks, Inc. so that such Registration Statement will be declared effective at 4:30 p.m., Eastern Time, on Thursday December 29, 2005, or as soon thereafter as practicable.

On behalf of Occam Networks, Inc. (the “Company”), the undersigned hereby acknowledges and agrees that:

•

should the United States Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking action with respect to the filing;

•

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

•

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.

Please advise the undersigned and Asaf Kharal (Tel: 650-320-4557, Fax: 650-493-6811) when the order permitting such Registration Statement to become effective is issued.

Sincerely,
OCCAM NETWORKS, INC.

Show Raw Text
CORRESP
1
filename1.htm

Acceleration Request

 OCCAM NETWORKS, INC.

 77 Robin Hill Road

 Santa Barbara, CA 93117

 Tel. (805) 692-2900, Fax (805) 692-2999

 December 22, 2005

 VIA EDGAR

 Securities
and Exchange Commission

 100 F Street N.E.

 Washington, DC 20549

Re:
Occam Networks, Inc.

Registration Statement on Form S-1 (File: 333-125061) – Rights Offering

Ladies and Gentlemen:

 We hereby request acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (the “Registration Statement”)
for Occam Networks, Inc. so that such Registration Statement will be declared effective at 4:30 p.m., Eastern Time, on Thursday December 29, 2005, or as soon thereafter as practicable.

 On behalf of Occam Networks, Inc. (the “Company”), the undersigned
hereby acknowledges and agrees that:

•

should the United States Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does
not foreclose the Commission from taking action with respect to the filing;

•

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

•

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.

 Please advise the undersigned and Asaf Kharal
(Tel: 650-320-4557, Fax: 650-493-6811) when the order permitting such Registration Statement to become effective is issued.

Sincerely,

OCCAM NETWORKS, INC.

By:

 /s/ Howard M. Bailey

 Howard M. Bailey

 Chief Financial Officer and
Corporate Secretary