SEC Company Response from SEABRIGHT INSURANCE HOLDINGS INC (CIK 0001267201) — Jan 19, 2005
SEABRIGHT INSURANCE HOLDINGS INC (CIK 0001267201)
Date: Jan. 19, 2005 · CIK: 0001267201 · Accession: 0000950124-05-000262
AI Filing Summary & Sentiment
File numbers found in text: 333-119111
Letter
Re: SeaBright Insurance Holdings, Inc. Registration Statement on Form S-1 File Number 333-119111
<PAGE> SEABRIGHT INSURANCE HOLDINGS, INC. 2101 4TH AVENUE, SUITE 1600 SEATTLE, WA 98121
January 19, 2005
VIA EDGAR
Securities and Exchange Commission Judiciary Plaza 450 Fifth Street, N.W. Washington, D.C. 20549 Mail Stop 3-09
Attn: Mr. Albert C. Lee
Ladies and Gentlemen:
We hereby request acceleration of the effective date of our Registration Statement on Form S-1, SEC File No. 333-119111, as amended, to 1:30 p.m., Eastern time, on Wednesday, January 19, 2005, or as soon thereafter as practicable. In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended (the "Act"), we hereby confirm that we are aware of our obligations under the Act. In addition, we acknowledge that:
o should the Securities and Exchange Commission (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;
o the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve us from our full responsibility for the adequacy and accuracy of the disclosure in the filing; and
o we may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact James S. Rowe of Kirkland & Ellis LLP, our special counsel, at (312) 861-2191, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter.
<PAGE>
Sincerely,
SEABRIGHT INSURANCE HOLDINGS, INC.
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SEABRIGHT INSURANCE HOLDINGS, INC.
2101 4TH AVENUE, SUITE 1600
SEATTLE, WA 98121
January 19, 2005
VIA EDGAR
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Mail Stop 3-09
Attn: Mr. Albert C. Lee
Re: SeaBright Insurance Holdings, Inc.
Registration Statement on Form S-1
File Number 333-119111
Ladies and Gentlemen:
We hereby request acceleration of the effective date of our
Registration Statement on Form S-1, SEC File No. 333-119111, as amended, to 1:30
p.m., Eastern time, on Wednesday, January 19, 2005, or as soon thereafter as
practicable. In accordance with Rule 461 promulgated under the Securities Act of
1933, as amended (the "Act"), we hereby confirm that we are aware of our
obligations under the Act. In addition, we acknowledge that:
o should the Securities and Exchange Commission (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;
o the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve us from our full responsibility for the adequacy and accuracy
of the disclosure in the filing; and
o we may not assert this action as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of
the United States.
Please contact James S. Rowe of Kirkland & Ellis LLP, our
special counsel, at (312) 861-2191, as soon as the registration statement has
been declared effective, or if you have any other questions or concerns
regarding this matter.
<PAGE>
Sincerely,
SEABRIGHT INSURANCE HOLDINGS, INC.
By: /s/ M. Philip Romney
---------------------------------
Name: M. Philip Romney
Title: Vice President - Finance
cc: James S. Rowe
2
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