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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

Date
February 8, 2005
Author
Not clearly detected
Form
CORRESP
Company
FTD Group, Inc. (CIK 0001283157)

Letter

FTD GROUP, INC. 3113 Woodcreek Drive

Downers Grove, Illinois 60515

February 4,

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.

Show Raw Text
CORRESP
1
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