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SEC Company Response from @ROAD, INC (CIK 0001109537) — Sep 14, 2005

@ROAD, INC (CIK 0001109537)
Date: Sept. 14, 2005 · CIK: 0001109537 · Accession: 0001104659-05-043987

AI Filing Summary & Sentiment

File numbers found in text: 333-124518

Date
September 14, 2005
Author
/s/ Krish Panu
Form
CORRESP
Company
@ROAD, INC (CIK 0001109537)

Letter

Securities and Exchange Commission Division of Corporation Finance Attention: Adam Halper Registration Statement on Form S-3 (as amended) (the “Registration Statement”) Filed on May 2, 2005 and amended on August 18, 2005 and September 14, File No. 333-124518

Re: @Road, Inc.

Dear Mr. Halper:

@Road, Inc., a Delaware corporation (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to make the above-captioned Registration Statement of the Company effective at 3:00 p.m., Washington, D.C. time, on Thursday, September 15, 2005, or as soon thereafter as possible. Please fax a copy of the order declaring the above captioned Registration Statement of the Company effective to our outside counsel, Heller Ehrman LLP, at (650) 324-6062, attention: Kristen Kercher.

In connection with this request for acceleration, the Company hereby acknowledges that:

• should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

• the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement 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 Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Should you have any questions regarding this request, please contact Kristen Kercher of Heller Ehrman LLP directly at (650) 233-8414. Thank you very much for your assistance with this matter.

Sincerely,
@Road, Inc.

Show Raw Text
CORRESP
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filename1.htm

September 14, 2005

VIA
FACSIMILE AND EDGAR (CORRESPONDENCE)

Securities and Exchange
Commission

Division of Corporation
Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Adam Halper

Re:          @Road, Inc.

Registration
Statement on Form S-3 (as amended) (the “Registration
Statement”)

Filed
on May 2, 2005 and amended on August 18, 2005 and September 14,
2005

File No. 333-124518

Dear Mr. Halper:

@Road, Inc.,
a Delaware corporation (the “Company”)
hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to
make the above-captioned Registration Statement of the Company effective at
3:00 p.m., Washington, D.C. time, on Thursday, September 15, 2005, or
as soon thereafter as possible.  Please
fax a copy of the order declaring the above captioned Registration Statement of
the Company effective to our outside counsel, Heller Ehrman LLP, at (650) 324-6062,
attention:  Kristen Kercher.

In
connection with this request for acceleration, the Company hereby acknowledges
that:

•              should
the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the
Registration Statement effective, it does not foreclose the Commission from
taking any action with respect to the Registration Statement;

•              the
action of the Commission or the Staff, acting pursuant to delegated authority,
in declaring the Registration Statement 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 Staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

Should
you have any questions regarding this request, please contact Kristen Kercher
of Heller Ehrman LLP directly at (650) 233-8414.  Thank you very much for your assistance with
this matter.

  Sincerely,

  @Road, Inc.

  /s/ Krish Panu

  Krish Panu

  Chief Executive Officer

  cc:

  James D. Fay,
  @Road, Inc.

  Jeffrey Li,
  @Road, Inc.

  Steven J. Tonsfeldt, Heller Ehrman LLP

  Amy E. Paye,
  Heller Ehrman LLP

  Kristen Kercher,
  Heller Ehrman LLP

2