SEC Company Response from FTD Group, Inc. (CIK 0001283157) — Feb 4, 2005
FTD Group, Inc. (CIK 0001283157)
Date: Feb. 4, 2005 · CIK: 0001283157 · Accession: 0001047469-05-002489
AI Filing Summary & Sentiment
File numbers found in text: 333-120723
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CORRESP
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filename1.htm
FTD GROUP, INC.
3113 Woodcreek Drive
Downers Grove, Illinois 60515
February 4,
2005
VIA EDGAR AND FACSIMILE
Securities
and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention:
Elaine Wolff
Michael McTiernan
Rachel Zablow
Donna DiSilvio
Re:
FTD Group, Inc.
Registration Statement on Form S-1 (File No. 333-120723), as amended
Ladies
and Gentlemen:
Pursuant
to Rule 461 of Regulation C under the Securities Act of 1933, as amended, FTD Group, Inc. hereby requests that the effective date of the above-referenced
Registration Statement be accelerated to, and that such Registration Statement be declared effective on, Tuesday, February 8, 2005 at 3:00 p.m., Washington, D.C. time, or as soon
thereafter as practicable, unless we or our outside counsel, Latham & Watkins LLP, request by telephone that such Registration Statement be declared effective at some other time.
FTD
Group, Inc. acknowledges that:
•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;
•the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve FTD Group, Inc. from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and
•FTD
Group, Inc. 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.
(Signature
Page Follows)
Securities
and Exchange Commission
Page 2
Very truly yours,
FTD Group, Inc.
By:
/s/ JON R. BURNEY Name: Jon R. Burney
Title: Vice President, General Counsel
and Secretary