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SEC Company Response from ASBURY AUTOMOTIVE GROUP INC (ABG) (CIK 0001144980) (ABG) — Sep 5, 2007

ASBURY AUTOMOTIVE GROUP INC (ABG) (CIK 0001144980)
Date: Sept. 5, 2007 · CIK: 0001144980 · Accession: 0001193125-07-195837

AI Filing Summary & Sentiment

File numbers found in text: 333-144342, 333-144346

Date
September 5, 2007
Author
Lynne A. Burgess
Form
CORRESP
Company
ASBURY AUTOMOTIVE GROUP INC (ABG) (CIK 0001144980)

Letter

Securities and Exchange Commission Attention: H. Christopher Owings Registration Statement on Form S-3 File No. 333-144342 Registration Statement on Form S-4 File No. 333-144346

Dear Mr. Owings:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, registrant Asbury Automotive Group, Inc. (the “Company”) hereby respectfully requests that each of the above-referenced Registration Statements (the “Registration Statements”) be declared effective at 3:00 p.m., Eastern Time, on September 6, 2007, or as soon thereafter as is practicable.

In connection with the foregoing request, the Company acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (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; (ii) 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 accuracy and adequacy of the disclosure in the filing; and (iii) 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.

As soon as the Securities and Exchange Commission has declared such Registration Statement effective, please call Marvin B. Tagaban at Cravath, Swaine & Moore LLP at (212) 474-1892, and then send written confirmation to the addresses listed on the covers of the respective Registration Statements.

Sincerely,
Lynne A. Burgess

Show Raw Text
CORRESP
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filename1.htm

Correspondence

 [Letterhead of]

 ASBURY AUTOMOTIVE GROUP, INC.

 September 5, 2007

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549-3561

 Attention: H. Christopher Owings

 Assistant Director

Re:
Asbury Automotive Group, Inc.

 Registration
Statement on Form S-3

 File No. 333-144342

 Registration Statement on Form S-4

 File No. 333-144346

 Dear Mr. Owings:

 Pursuant to Rule 461 promulgated
under the Securities Act of 1933, as amended, registrant Asbury Automotive Group, Inc. (the “Company”) hereby respectfully requests that each of the above-referenced Registration Statements (the “Registration Statements”) be
declared effective at 3:00 p.m., Eastern Time, on September 6, 2007, or as soon thereafter as is practicable.

 In connection with the
foregoing request, the Company acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (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; (ii) 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 accuracy and adequacy of the disclosure in the filing; and (iii) 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.

 As soon as the Securities and Exchange Commission has declared such Registration Statement effective,
please call Marvin B. Tagaban at Cravath, Swaine & Moore LLP at (212) 474-1892, and then send written confirmation to the addresses listed on the covers of the respective Registration Statements.

Sincerely,

 Lynne A. Burgess

 Vice President, General
Counsel & Secretary

 2