SEC Company Response from NUVIM INC (CIK 0001170652) — Jun 16, 2005
NUVIM INC (CIK 0001170652)
Date: June 16, 2005 · CIK: 0001170652 · Accession: 0001133796-05-000146
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File numbers found in text: 333-120938
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CORRESP 1 filename1.htm PAULSON INVESTMENT COMPANY, INC. LETTERHEAD June 16, 2005 United States Securities & Exchange Commission Mr. John Reynolds Assistant Director Office of Emerging Growth Companies Division of Corporate Finance 450 Fifth Street, N.W. Washington, DC 20549 RE: NuVim, Inc. Registration Statement Form SB-2, File Number 333-120938 In connection with the above referenced offering and in compliance with Rule 418 (a) (7) the following is the approximate distribution of the preliminary prospectus, dated February 8, 2005 and the amended preliminary prospectus dated April 4, 2005, the second amended preliminary prospectus dated May 4, 2005 and the third amended preliminary prospectus dated June 6, 2005. Distributions of the preliminary prospectus were made between February 8, 2005 and the present date. Approximately 3700 preliminary prospectus dated February 8, 2005 were distributed to approximately 900 prospective Underwriters and Dealers. Approximately 2200 preliminary prospectus were delivered to approximately 1800 individuals and 400 preliminary prospectus were delivered to approximately 150 institutional investors. Approximately 3350 amended preliminary prospectus dated April 4, 2005 were distributed to approximately 60 prospective Underwriter and Dealers. Approximately 1500 amended preliminary prospectus were delivered to approximately 1500 individuals and 250 amended preliminary prospectus were delivered to approximately 100 institutional investors. Approximately 3700 amended preliminary prospectus dated May 4, 2005 were distributed to approximately 45 prospective Underwriter and Dealers. Approximately 1500 amended preliminary prospectus were delivered to approximately 1500 individuals and 200 amended preliminary prospectus were delivered to approximately 75 institutional investors. Approximately 1000 amended preliminary prospectus dated June 6, 2005 were distributed to approximately 25 prospective Underwriter and Dealers. Approximately 400 amended preliminary prospectus were delivered to approximately 400 individuals and 150 amended preliminary prospectus were delivered to approximately 50 institutional investors. Very Truly Yours, /s/ TRENT D. DAVIS Trent D. Davis CEO 811 S.W. Naito Parkway • Suite 200 • Portland, Oregon 97204 • (503) 243-6000 Member NASD & SIPC