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
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File numbers found in text: 333-119986
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CORRESP
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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