SEC Company Response from WHITTIER ENERGY CORP (CIK 0001108520) — Dec 22, 2004
WHITTIER ENERGY CORP (CIK 0001108520)
Date: Dec. 22, 2004 · CIK: 0001108520 · Accession: 0001047469-04-038192
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File numbers found in text: 333-119048
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CORRESP
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[Whittier Letterhead]
December 22,
2004
Via EDGAR Electronic Transmission
and Facsimile: (202) 942-9528
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn:
Mr. Alex Shukhman
Re:Whittier
Energy Corporation
Registration Statement on Form SB-2
File No. 333-119048
Ladies
and Gentlemen:
Pursuant
to Rule 461 of the rules and regulations promulgated under the Securities Act of 1933, as amended, Whittier Energy Corporation ("Registrant") hereby requests that the
Securities and Exchange Commission (the "Commission") take appropriate action to accelerate the effectiveness of the above-referenced Registration Statement on Form SB-2 ("Registration
Statement") so that it will become effective Monday, December 27, 2004, at 5:00 p.m. Eastern Time, or as soon thereafter as practicable.
Registrant
is aware of its respective responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed
public offering of the securities specified in the Registration Statement. Registrant hereby acknowledges that if the Commission or its staff, acting pursuant to delegated authority, declares the
Registration Statement effective, such action does not foreclose the Commission from taking any action with respect to the Registration Statement. Registrant also acknowledges that the action of the
Commission or its staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve Registrant from its full responsibility for the adequacy and
accuracy of the disclosure in the Registration Statement. Furthermore, Registrant acknowledges that it may not assert such action by the Commission as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.
Please
address any questions or comments with respect to this request to our counsel, Thompson & Knight LLP, by contacting Dallas Parker (telephone:
(713) 951-5800; facsimile (832) 397-8110).
Very truly yours,
WHITTIER ENERGY CORPORATION
By:
/s/ MICHAEL B. YOUNG Michael B. Young
Chief Financial Officer
cc:
Dallas Parker, Esq.