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SEC Company Response from KMG America CORP (CIK 0001299210) — Dec 13, 2004

KMG America CORP (CIK 0001299210)
Date: Dec. 13, 2004 · CIK: 0001299210 · Accession: 0001047469-04-036897

AI Filing Summary & Sentiment

File numbers found in text: 333-117911

Date
December 14, 2004
Author
KMG AMERICA CORPORATION
Form
CORRESP
Company
KMG America CORP (CIK 0001299210)

Letter

VIA EDGAR AND FACSIMILE Securities and Exchange Commission Washington, D.C. 20549 Attention: Ms. Sonia Barros KMG America Corporation Registration Statement on Form S-1 (File No. 333-117911)

Dear Ms. Barros:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, KMG America Corporation (the "Company") hereby requests acceleration of effectiveness of the above-captioned Registration Statement to 4:00 p.m., New York City time, on Tuesday, December 14, 2004, or as soon thereafter as practicable.

The disclosure in the filing is the responsibility of the Company. The Company acknowledges and represents to the Securities and Exchange Commission that:

(i) 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;

(ii) 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 disclosures in the filing; and

(iii) the Company will 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.

Very truly yours,
KMG AMERICA CORPORATION

Show Raw Text
CORRESP
1
filename1.htm

KMG AMERICA CORPORATION
  6306 Maple Ridge

Excelsior, Minnesota 55331

December 13,
2004

VIA EDGAR AND FACSIMILE

Securities
and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Ms. Sonia Barros

KMG
America Corporation

Registration Statement on Form S-1 (File No. 333-117911)

Dear
Ms. Barros:

        Pursuant
to Rule 461 under the Securities Act of 1933, as amended, KMG America Corporation (the "Company") hereby requests acceleration of effectiveness of the above-captioned
Registration Statement to 4:00 p.m., New York City time, on Tuesday, December 14, 2004, or as soon thereafter as practicable.

        The
disclosure in the filing is the responsibility of the Company. The Company acknowledges and represents to the Securities and Exchange Commission that:

          (i)  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;

         (ii)  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 disclosures in the filing; and

        (iii)  the
Company will 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.

Very truly yours,

KMG AMERICA CORPORATION

By:

/s/  KENNETH U. KUK

Name:

Kenneth U. Kuk

Title:

Chairman, President & Chief Executive Officer