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SEC Comment Letter for EAST KANSAS AGRI ENERGY LLC (CIK 0001170106) — Apr 25, 2005

EAST KANSAS AGRI ENERGY LLC (CIK 0001170106)
Date: April 25, 2005 · CIK: 0001170106 · Accession: 0000000000-05-019964

AI Filing Summary & Sentiment

File numbers found in text: 333-121323

Date
April 13, 2005
Author
Jennifer Hardy
Form
UPLOAD
Company
EAST KANSAS AGRI ENERGY LLC (CIK 0001170106)

Letter

April 13, 2005 via U.S. mail and facsimile William R. Pracht President East Kansas Agri-Energy, L.L.C. P.O. Box 225 2101/2 East 4th Avenue Garnett, Kansas 66093

Re: Draft Supplemental Sales Material received March 1, 2005 File No.: 333-121323

Dear Pracht,

We have reviewed the materials you provided and have the following comments. Feel free to call us at the telephone numbers listed at the end of this letter.

Proposed Sales Material

1. Item 19 of Industry Guide 5 states that the sales material should present a balanced discussion of both the risk and reward. Thus, for example, when you talk about the increasing demand for ethanol, you should note the dependence on and the potential loss of favorable tax benefits. The sales material should be balanced so that whenever a benefit is claimed, the corresponding detriment is described as well. Please revise all of the sales material in accordance with this principle.

2. We are unable to locate in the prospectus, all of the figures and statistics that you refer to in the sales materials. For example, we are unable to locate in the prospectus, the information regarding Sorghum and Corn Production within 50 Miles of Garnett, Kansas. The sales material cannot contain information that is different from or not in the prospectus. Please revise the sales materials as appropriate or help us understand how this information is consistent with the prospectus.

Closing Comments

As appropriate, please amend your sales materials in response to these comments. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

Please direct questions to Craig Slivka at (202) 942-7470 or the undersigned at (202) 942-1950.

Sincerely,
Jennifer Hardy
Branch Chief

Show Raw Text
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<TEXT>

April 13, 2005

via U.S. mail and facsimile

William R. Pracht
President
East Kansas Agri-Energy, L.L.C.
P.O. Box 225
2101/2 East 4th Avenue
Garnett, Kansas 66093

Re:	Draft Supplemental Sales Material received March 1, 2005
      File No.: 333-121323

Dear Pracht,

      We have reviewed the materials you provided and have the
following comments.  Feel free to call us at the telephone numbers
listed at the end of this letter.

Proposed Sales Material

1. Item 19 of Industry Guide 5 states that the sales material
should
present a balanced discussion of both the risk and reward.  Thus,
for
example, when you talk about the increasing demand for ethanol,
you
should note the dependence on and the potential loss of favorable
tax
benefits.  The sales material should be balanced so that whenever
a
benefit is claimed, the corresponding detriment is described as
well.
Please revise all of the sales material in accordance with this
principle.

2. We are unable to locate in the prospectus, all of the figures
and
statistics that you refer to in the sales materials.  For example,
we
are unable to locate in the prospectus, the information regarding
Sorghum and Corn Production within 50 Miles of Garnett, Kansas.
The
sales material cannot contain information that is different from
or
not in the prospectus.  Please revise the sales materials as
appropriate or help us understand how this information is
consistent
with the prospectus.

Closing Comments

      As appropriate, please amend your sales materials in
response
to these comments.  Please furnish a cover letter with your
amendment
that keys your responses to our comments and provides any
requested
supplemental information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

      Please direct questions to Craig Slivka at (202) 942-7470 or
the undersigned at (202) 942-1950.

							Sincerely,

							Jennifer Hardy
							Branch Chief

cc: 	William E. Hannigan, Esq.
	Fax (515) 283-0231
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

         DIVISION OF
CORPORATION FINANCE

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