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SEC Company Response from QXO, Inc. (QXO, QXO-PB) (CIK 0001236275) (QXO) — Dec 4, 2006

QXO, Inc. (QXO, QXO-PB) (CIK 0001236275)
Date: Dec. 4, 2006 · CIK: 0001236275 · Accession: 0000922423-06-001505

Offering / Registration Process

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File numbers found in text: 333-133924

Date
Dec. 4, 2006
Author
submitted
Form
CORRESP
Company
QXO, Inc. (QXO, QXO-PB) (CIK 0001236275)

Letter

Sub Filer Ccc

Trey Resources, Inc.

Regent Street, Suite 520

Livingston, New Jersey 07039

December 4,

VIA EDGAR and FACSIMILE

Division of Corporation Finance

Mail Stop

United States Securities and Exchange Commission

F Street, N.E.

Washington, D.C. 20549

Re: Trey Resources, Inc.

Registration Statement on Form SB-2

SEC File No. 333-133924

Ladies and Gentlemen:

On behalf of Trey Resources, Inc. (the “Company”), the undersigned hereby respectfully requests, pursuant to Rule 461 under the Securities Act of 1933, that the effective date of the above-captioned Registration Statement be accelerated to 9:30 a.m., New York City time, on December 6, 2006, or as soon as practicable thereafter.

The undersigned, on behalf of the Company, hereby acknowledges that:

•

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure of the filing; and

•

the Company may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We ask that Christopher S. Auguste (telephone 212-715-9265) be advised upon the Registration Statement becoming effective.

Respectfully
submitted,
TREY
RESOURCES,
INC.

Show Raw Text
CORRESP
1
filename1.htm

      Sub Filer Ccc

    Trey
      Resources, Inc.

    5
      Regent
      Street, Suite 520

    Livingston,
      New Jersey 07039

                    December
      4,
      2006

    VIA
      EDGAR and FACSIMILE

    Division
      of Corporation Finance

    Mail
      Stop
      7010

    United
      States Securities and Exchange Commission

    100
      F
      Street, N.E.

    Washington,
      D.C. 20549

    Re: Trey
      Resources, Inc.

    Registration
      Statement on Form SB-2

    SEC
      File No. 333-133924

    Ladies
      and Gentlemen:

    On
      behalf
      of Trey Resources, Inc. (the “Company”),
      the
      undersigned hereby respectfully requests, pursuant to Rule 461 under the
      Securities Act of 1933, that the effective date of the above-captioned
      Registration Statement be accelerated to 9:30 a.m., New York City time, on
      December 6, 2006, or as soon as practicable thereafter.

    The
      undersigned, on behalf of the Company, hereby acknowledges that:

              •

              should
                the Commission or the staff, acting pursuant to delegated authority,
                declare the filing effective, it does not foreclose the Commission
                from
                taking any action with respect to the
                filing;

              •

              the
                action of the Commission or the staff, acting pursuant to delegated
                authority, in declaring the filing effective, does not relieve the
                Company
                from its full responsibility for the adequacy and accuracy of the
                disclosure of the filing; and

              •

              the
                Company may not assert the staff comments and the declaration of
                effectiveness as a defense in any proceeding initiated by the Commission
                or any person under the federal securities laws of the United
                States.

    We
      ask
      that Christopher S. Auguste (telephone 212-715-9265) be advised upon the
      Registration Statement becoming effective.

                    Respectfully
      submitted,

                    TREY
      RESOURCES,
      INC.

                    By: /s/
      Mark
      Meller

      Name: Mark Meller

      Title:   Chief Executive Officer

    cc:
      Christopher S. Auguste