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SEC Company Response from KANBAY INTERNATIONAL INC (CIK 0001125011) — Dec 3, 2004

KANBAY INTERNATIONAL INC (CIK 0001125011)
Date: Dec. 3, 2004 · CIK: 0001125011 · Accession: 0001047469-04-036137

AI Filing Summary & Sentiment

File numbers found in text: 333-119986

Date
December 7, 2004
Author
By
Form
CORRESP
Company
KANBAY INTERNATIONAL INC (CIK 0001125011)

Letter

Kanbay International, Inc.

6400 Shafer Court

Rosemont, Illinois 60018

December 3, 2004

VIA FACSIMILE AND EDGAR

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:Kanbay International, Inc.

Form S-1 Registration Statement

(No. 333-119986)

Ladies and Gentlemen:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Kanbay International, Inc. hereby requests that the effective date of the Registration Statement described above be accelerated so that such Registration Statement may become effective at 2:00 p.m. (Washington, D.C. time) on Tuesday, December 7, 2004, or as soon thereafter as practicable.

[signature page follows]

Respectfully submitted,

KANBAY INTERNATIONAL, INC.

By:

/s/ RAYMOND J. SPENCER Raymond J. Spencer

Chairman and Chief Executive Officer

Kanbay International, Inc.

6400 Shafer Court

Rosemont, Illinois 60018

December 3, 2004

VIA FACSIMILE AND EDGAR

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:Kanbay International, Inc.

Form S-1 Registration Statement

(No. 333-119986)

Ladies and Gentlemen:

Concurrently with the transmission of this letter, Kanbay International, Inc. (the "Registrant") has submitted a letter requesting that the Securities and Exchange Commission (the "Commission") accelerate the effectiveness of the Registration Statement described above.

In connection with the Registrant's foregoing request to accelerate the effectiveness of the Registration Statement, the Registrant hereby acknowledges that:

•should the Commission or 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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

•the Registrant 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.

Respectfully submitted,
KANBAY INTERNATIONAL, INC.

Show Raw Text
CORRESP
1
filename1.htm

Kanbay International, Inc.

6400 Shafer Court

Rosemont, Illinois 60018

December
3, 2004

VIA FACSIMILE AND EDGAR

Securities
and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:Kanbay
International, Inc.

Form S-1 Registration Statement

(No. 333-119986)

Ladies
and Gentlemen:

        Pursuant
to Rule 461 of the Securities Act of 1933, as amended, Kanbay International, Inc. hereby requests that the effective date of the Registration Statement described
above be accelerated so that such Registration Statement may become effective at 2:00 p.m. (Washington, D.C. time) on Tuesday, December 7, 2004, or as soon thereafter as
practicable.

[signature page follows]

Respectfully submitted,

KANBAY INTERNATIONAL, INC.

By:

/s/  RAYMOND J. SPENCER       Raymond J. Spencer

Chairman and Chief Executive Officer

Kanbay International, Inc.

6400 Shafer Court

Rosemont, Illinois 60018

December
3, 2004

VIA FACSIMILE AND EDGAR

Securities
and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:Kanbay
International, Inc.

Form S-1 Registration Statement

(No. 333-119986)

Ladies
and Gentlemen:

        Concurrently
with the transmission of this letter, Kanbay International, Inc. (the "Registrant") has submitted a letter requesting that the Securities and Exchange Commission (the
"Commission") accelerate the effectiveness of the Registration Statement described above.

        In
connection with the Registrant's foregoing request to accelerate the effectiveness of the Registration Statement, the Registrant hereby acknowledges that:

•should
the Commission or 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 Registrant from
its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

•the
Registrant 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.

Respectfully submitted,

KANBAY INTERNATIONAL, INC.

By:

/s/  RAYMOND J. SPENCER       Raymond J. Spencer

Chairman and Chief Executive Officer

cc:Mark
P. Shuman

Robert D. Bell