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SEC Company Response from FORE HOLDINGS LLC (CIK 0001216127) — Sep 16, 2005

FORE HOLDINGS LLC (CIK 0001216127)
Date: Sept. 16, 2005 · CIK: 0001216127 · Accession: 0001193125-05-186579

AI Filing Summary & Sentiment

Date
September 15, 2005
Author
/s/ Eric Orsic
Form
CORRESP
Company
FORE HOLDINGS LLC (CIK 0001216127)

Letter

United States Securities and Exchange Commission Division of Corporation Finance Re: FORE Holdings L.L.C. File No. 0-50161 Preliminary Proxy Statement on Schedule 14A Filed on August 22, 2005

Dear Ms. McManus:

Further to our telephone conference on September 15, 2005, on behalf of FORE Holdings L.L.C. (the “Company”), this letter responds to the Staff’s oral comments with respect to the above-referenced filing.

1. The Company believes that the fair market value of its investment in Overlook Associates as of June 30, 2005 was $52 million. As of such date, the Company had entered into a preliminary agreement relating to the sale of its interest in Overlook Associates which would yield net proceeds to the Company of that amount. In addition, the Company was actively negotiating definitive documents with respect to the transaction at that time.

2. As of June 30, 2005, the Company’s assets, other than its investment in Hewitt Associates and its investment in Overlook Associates, consisted of cash and cash equivalents, rent receivable, amounts due from owners and a direct interest in one additional parcel of real estate. Further, we have been advised that the Company had invested its cash and cash equivalents in money market mutual funds. We believe that these others assets do not constitute “investment securities” within the meaning of Section 3(a)(1)(C) of the Investment Company Act.

September 15, 2005

Page 2

If you have any questions, please do not hesitate to contact the undersigned at (312) 984-7617.

Sincerely,
/s/ Eric Orsic

Show Raw Text
CORRESP
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filename1.htm

Letter of Correspondence

 [Letterhead of McDermott Will & Emery LLP]

 September 15, 2005

 VIA FACSIMILE AND EDGAR

 Ms. Amanda McManus

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
FORE Holdings L.L.C.

File No. 0-50161

Preliminary Proxy Statement on Schedule 14A

Filed on August 22, 2005

 Dear Ms. McManus:

 Further to our telephone
conference on September 15, 2005, on behalf of FORE Holdings L.L.C. (the “Company”), this letter responds to the Staff’s oral comments with respect to the above-referenced filing.

1.
The Company believes that the fair market value of its investment in Overlook Associates as of June 30, 2005 was $52 million. As of such date, the Company had entered into a
preliminary agreement relating to the sale of its interest in Overlook Associates which would yield net proceeds to the Company of that amount. In addition, the Company was actively negotiating definitive documents with respect to the transaction at
that time.

2.
As of June 30, 2005, the Company’s assets, other than its investment in Hewitt Associates and its investment in Overlook Associates, consisted of cash and cash equivalents,
rent receivable, amounts due from owners and a direct interest in one additional parcel of real estate. Further, we have been advised that the Company had invested its cash and cash equivalents in money market mutual funds. We believe that these
others assets do not constitute “investment securities” within the meaning of Section 3(a)(1)(C) of the Investment Company Act.

 September 15, 2005

 Page 2

 If you have any questions, please do not hesitate to contact the undersigned
at (312) 984-7617.

 Sincerely,

 /s/ Eric Orsic

 Eric Orsic

 cc: David L. Hunt, Chairman