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SEC Company Response from NUVIM INC (CIK 0001170652) — Jun 16, 2005

NUVIM INC (CIK 0001170652)
Date: June 16, 2005 · CIK: 0001170652 · Accession: 0001133796-05-000147

AI Filing Summary & Sentiment

File numbers found in text: 333-120938

Date
June 16, 2005
Author
By
Form
CORRESP
Company
NUVIM INC (CIK 0001170652)

Letter

RE:

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

Via Facsimile

NuVim, Inc. Registration Statement Form SB-2, File Number 333-120938

Pursuant to Rule 461 of the Securities Act of 1933, as amended, the undersigned hereby requests acceleration of the effective date of the above referenced registration statement to Monday, June 20th, 2005 4:15 p.m. Eastern Time or as soon thereafter as is practicable.

Sincerely,
PAULSON INVESTMENT COMPANY, INC.

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CORRESP
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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

Via Facsimile

RE:

NuVim, Inc.
   Registration Statement Form SB-2, File Number 333-120938

          Pursuant to Rule 461 of the Securities Act of 1933, as amended, the undersigned hereby requests acceleration of the effective date of the above referenced registration statement to Monday, June 20th, 2005 4:15 p.m. Eastern Time or as soon thereafter as is practicable.

Sincerely,

  PAULSON INVESTMENT COMPANY,   INC.

  By:

  /s/ TRENT D. DAVIS

  Trent D.   Davis
   CEO

811 S.W. Naito Parkway  •  Suite 200  •  Portland, Oregon 97204  •  (503) 243-6000

Member NASD & SIPC