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SEC Company Response from COMPASS MINERALS GROUP INC (CIK 0001160726) — Dec 28, 2005

COMPASS MINERALS GROUP INC (CIK 0001160726)
Date: Dec. 28, 2005 · CIK: 0001160726 · Accession: 0000950137-05-015342

AI Filing Summary & Sentiment

File numbers found in text: 333-82700

Referenced dates: December 2, 2005

Date
December 28, 2005
Author
/s/ Gregory G. Johnson
Form
CORRESP
Company
COMPASS MINERALS GROUP INC (CIK 0001160726)

Letter

Securities and Exchange Commission Attn: John Cash Accounting Branch Chief 100 F Street, NE Washington, DC 20549 Form 10-K for the fiscal year ended December 31, 2004 Form 10-Q for the quarter ended September 30, 2005 File No. 333-82700

RE: Compass Minerals Group, Inc.

Dear Mr. Cash:

This letter is to follow up on our letter to you dated December 12, 2005 and to formally respond to your letter dated December 2, 2005 to our client, Compass Minerals Group, Inc. ("CMG"), regarding Staff comments to CMG's Form 10-K for fiscal 2004 and Form 10-Q for the period ended September 30, 2005. In your December 2, 2005 letter the Staff expresses certain comments to be considered for CMG's future filings with the Commission.

As discussed in our December 12, 2005 letter, we now wish to inform you that CMG has recently completed a tender offer for its publicly held debt securities, amended its indenture for such securities to delete Commission filing obligations, and has filed a Form 15 to deregister such securities under the Securities Exchange Act of 1934. Therefore, CMG does not anticipate that it will make any future filings with the Commission. As such, per our conversation with Anne McConnell we trust that no substantive response by CMG to your December 2, 2005 letter is necessary.

Very truly yours,
/s/ Gregory G. Johnson

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
<PAGE>

                                                         Gregory G. Johnson
                                                         Partner
                                                         Direct: 816-374-3227
                                                         ggjohnson@bryancave.com

December 28, 2005

Securities and Exchange Commission
Attn:  John Cash
Accounting Branch Chief
100 F Street, NE
Washington, DC 20549

RE:      Compass Minerals Group, Inc.

                  Form 10-K for the fiscal year ended December 31, 2004

                  Form 10-Q for the quarter ended September 30, 2005

                           File No. 333-82700

Dear Mr. Cash:

This letter is to follow up on our letter to you dated December 12, 2005 and to
formally respond to your letter dated December 2, 2005 to our client, Compass
Minerals Group, Inc. ("CMG"), regarding Staff comments to CMG's Form 10-K for
fiscal 2004 and Form 10-Q for the period ended September 30, 2005. In your
December 2, 2005 letter the Staff expresses certain comments to be considered
for CMG's future filings with the Commission.

As discussed in our December 12, 2005 letter, we now wish to inform you that CMG
has recently completed a tender offer for its publicly held debt securities,
amended its indenture for such securities to delete Commission filing
obligations, and has filed a Form 15 to deregister such securities under the
Securities Exchange Act of 1934. Therefore, CMG does not anticipate that it will
make any future filings with the Commission. As such, per our conversation with
Anne McConnell we trust that no substantive response by CMG to your December 2,
2005 letter is necessary.

Very truly yours,

/s/  Gregory G. Johnson

Gregory G. Johnson

GGJ:mb

cc:      Marie Trimeloni, Staff Accountant

         Anne McConnell, Review Accountant

         Rodney L. Underdown, Compass Minerals Group, Inc.

</TEXT>
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