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SEC Company Response from Charlie's Holdings, Inc. (CHUC) (CIK 0001134765) (CHUC) — May 23, 2005

Charlie's Holdings, Inc. (CHUC) (CIK 0001134765)
Date: May 23, 2005 · CIK: 0001134765 · Accession: 0001047469-05-015546

AI Filing Summary & Sentiment

File numbers found in text: 333-124897

Date
May 24, 2005
Author
/s/ GARY A. AGRON
Form
CORRESP
Company
Charlie's Holdings, Inc. (CHUC) (CIK 0001134765)

Letter

Securities and Exchange Commission File Number 333-124897 Attn: Song Brandon Division of Corporation Finance

Dear Ms. Brandon:

On behalf of VitaCube Systems Holdings, Inc. (the "Company"), we herewith request acceleration of the effective date of the offering to Tuesday, May 24, 2005 at 3:00PM Eastern Daylight Time, or as soon as practicable thereafter.

We acknowledge that:

•Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any 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.

Very truly yours,
/s/ GARY A. AGRON

Show Raw Text
CORRESP
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filename1.htm

LAW OFFICE OF GARY A. AGRON
  5445 DTC Parkway, Suite 520

Greenwood Village, Colorado 80111

Telephone: (303) 770-7254

Facsimile: (303) 770-7257

May 23,
2005

Securities
and Exchange Commission

Judiciary Plaza

450 Fifth Street NW

Washington, D.C. 20549

RE:

VitaCube Systems Holdings, Inc.; Form S-3

File Number 333-124897

Attn:

Song Brandon

Division of Corporation Finance

Dear
Ms. Brandon:

        On
behalf of VitaCube Systems Holdings, Inc. (the "Company"), we herewith request acceleration of the effective date of the offering to Tuesday, May 24, 2005 at 3:00PM
Eastern Daylight Time, or as soon as practicable thereafter.

        We
acknowledge that:

•Should
the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any 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.

Very truly yours,

/s/  GARY A. AGRON

Gary A. Agron

Attorney in Fact for

VitaCube Systems Holdings, Inc.

GA/jp