SEC Company Response from SPIRIT FINANCE CORP (CIK 0001277406) — Dec 13, 2004

SPIRIT FINANCE CORP (CIK 0001277406)
Date: Dec. 13, 2004 · CIK: 0001277406 · Accession: 0001047469-04-036895

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AI Filing Summary & Sentiment

File numbers found in text: 333-119810

Date

December 13, 2004

Author

Not clearly detected

Form

CORRESP

Company

SPIRIT FINANCE CORP (CIK 0001277406)

Letter

VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Washington, DC 20549 Re:Spirit Finance Corporation Registration Statement on Form S-11 Commission File No. 333-119810

Dear Ms. Garnett:

On behalf of Spirit Finance Corporation, in connection with the above-referenced Registration Statement, we hereby request that said Registration Statement be accelerated and declared effective pursuant to Section 8(a) of the Securities Act of 1933 at 1:00 p.m., Eastern Time, Wednesday, December 15, 2004, or as soon thereafter as practicable.

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 in the filing; and

•the company 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.

Spirit Finance Corporation

/s/ CATHERINE LONG Catherine Long, Chief Financial Officer

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CORRESP
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SPIRIT FINANCE CORPORATION

14631 North Scottsdale Road, Suite 200

Scottsdale, Arizona 85254-2711

(480) 606-0820

December 13, 2004

VIA EDGAR

Ms. Karen Garnett, Assistant Director

Division of Corporation Finance

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, DC 20549

Re:Spirit
Finance Corporation

Registration Statement on Form S-11

Commission File No. 333-119810

Dear
Ms. Garnett:

        On
behalf of Spirit Finance Corporation, in connection with the above-referenced Registration Statement, we hereby request that said Registration Statement be accelerated and declared
effective pursuant to Section 8(a) of the Securities Act of 1933 at 1:00 p.m., Eastern Time, Wednesday, December 15, 2004, or as soon thereafter as practicable.

        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 in the filing; and

•the
company 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.

Spirit Finance Corporation

/s/  CATHERINE LONG       Catherine Long, Chief Financial Officer

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