SEC Company Response from DiamondRock Hospitality Co (DRH) (CIK 0001298946) (DRH) — May 3, 2005
DiamondRock Hospitality Co (DRH) (CIK 0001298946)
Date: May 3, 2005 · CIK: 0001298946 · Accession: 0001193125-05-094137
AI Filing Summary & Sentiment
File numbers found in text: 333-12305
Letter
VIA EDGAR AND VIA HAND DELIVERY Division of Corporation Finance Securities and Exchange Commission Washington, DC 20549 Re: DiamondRock Hospitality Company Registration Statement on Form S-11 Filed March 1, 2005 Registration No. 333-12305
Dear Ms. Wolff and Mr. McTiernan:
Reference is hereby made to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to the Registration Statement on Form S-11 (the “Registration Statement”) of DiamondRock Hospitality Company (the “Company”) filed with the Commission on March 1, 2005, as amended pursuant to Amendment No. 1 to the Registration Statement filed with the Commission on April 1, 2005, as set forth in your letter, dated April 12, 2005 (the “Comment Letter”), to Mr. William McCarten, Chairman of the Board and Chief Executive Officer of the Company. Reference is also made to the draft opinion of Goodwin Procter LLP (the “Opinion”) supplementally filed with the Commission as Annex A to the Company’s initial response letter filed with the Commission on April 1, 2005.
Pursuant to comment No. 20 of the Comment Letter, Goodwin Procter LLP hereby supplementally confirms to the Staff that it concurs with the Staff’s understanding that the reference and limitation to Maryland General Corporation Law set forth in the Opinion includes the statutory provisions and applicable provisions of the Maryland Constitution and reported judicial decisions interpreting these laws.
If you should have any questions regarding this response to comment No. 20 of the Comment Letter, please do not hesitate to call Suzanne D. Lecaroz at (617) 570-1306.
Sincerely,
/s/ Goodwin Procter LLP
Show Raw Text
CORRESP 1 filename1.htm Correspondence May 3, 2005 VIA EDGAR AND VIA HAND DELIVERY Elaine Wolff, Special Counsel Michael McTiernan, Attorney-Advisor Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549 Re: DiamondRock Hospitality Company Registration Statement on Form S-11 Filed March 1, 2005 Registration No. 333-12305 Dear Ms. Wolff and Mr. McTiernan: Reference is hereby made to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to the Registration Statement on Form S-11 (the “Registration Statement”) of DiamondRock Hospitality Company (the “Company”) filed with the Commission on March 1, 2005, as amended pursuant to Amendment No. 1 to the Registration Statement filed with the Commission on April 1, 2005, as set forth in your letter, dated April 12, 2005 (the “Comment Letter”), to Mr. William McCarten, Chairman of the Board and Chief Executive Officer of the Company. Reference is also made to the draft opinion of Goodwin Procter LLP (the “Opinion”) supplementally filed with the Commission as Annex A to the Company’s initial response letter filed with the Commission on April 1, 2005. Pursuant to comment No. 20 of the Comment Letter, Goodwin Procter LLP hereby supplementally confirms to the Staff that it concurs with the Staff’s understanding that the reference and limitation to Maryland General Corporation Law set forth in the Opinion includes the statutory provisions and applicable provisions of the Maryland Constitution and reported judicial decisions interpreting these laws. If you should have any questions regarding this response to comment No. 20 of the Comment Letter, please do not hesitate to call Suzanne D. Lecaroz at (617) 570-1306. Sincerely, /s/ Goodwin Procter LLP Goodwin Procter LLP Securities and Exchange Commission Page 2 Enclosures cc: William W. McCarten John L. Williams Mark W. Brugger Michael D. Schecter Sean M. Mahoney Gilbert G. Menna David C. Wright Cyane B. Crump Richard Nadeau Douglas Sweeney