SEC Company Response from Tarpon Industries, Inc. (CIK 0001303565) — Feb 11, 2005
Tarpon Industries, Inc. (CIK 0001303565)
Date: Feb. 11, 2005 · CIK: 0001303565 · Accession: 0000950124-05-000771
AI Filing Summary & Sentiment
File numbers found in text: 333-120117
Letter
Re: Tarpon Industries, Inc. Registration No. 333-120117 ---------------------------------------------------
<PAGE> JOSEPH GUNNAR & CO., LLC 30 Broad Street New York, NY 10004
February 11, 2005
Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549
Ladies and Gentlemen:
We hereby withdraw our February 11, 2005 request to accelerate the above-captioned Registration Statement, so that it would become effective at 10:00 a.m. Eastern time on February 11, 2005 or as soon thereafter as is practicable.
Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Securities Act"), we, as representative of the several Underwriters, wish to advise you that in connection with the above-captioned Registration Statement, copies of the Preliminary Prospectus dated February 3, 2005 were distributed as follows:
<TABLE> <CAPTION> Underwriter Date(s) Copies ----------- ------- ------ <S> <C> <C> Joseph Gunnar & Co., LLC 02.04.05 - 02.05.05 550 LaSalle St. Securities Corp. 02.04.05 - 02.07.05 300 Newbridge Securities Corporation 02.04.05 - 02.07.05 250 ----
Total: 1,100 </TABLE>
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act, we hereby join in the request of Tarpon Industries, Inc. to accelerate the above-captioned Registration Statement, relating to the offering of up to 3,277,500 common shares, no par value, of Tarpon Industries, Inc. in its initial pubic offering and 758,800 common shares in a subsequent re-sale of common shares by selling shareholders, so that it will become effective at 10:00 a.m. Eastern time on February 14, 2005 or as soon thereafter as is practicable.
The underwriters acknowledge that (1) 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, (2) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing
<PAGE>
effective, does not relieve the underwriters from their full responsibility for the adequacy and accuracy of the disclosure in the filing, and (3) the underwriters 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.
Very truly yours,
JOSEPH GUNNAR & CO, LLC
REPRESENTATIVE OF THE
SEVERAL UNDERWRITERS
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JOSEPH GUNNAR & CO., LLC
30 Broad Street
New York, NY 10004
February 11, 2005
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Tarpon Industries, Inc. Registration No. 333-120117
---------------------------------------------------
Ladies and Gentlemen:
We hereby withdraw our February 11, 2005 request to accelerate the
above-captioned Registration Statement, so that it would become effective at
10:00 a.m. Eastern time on February 11, 2005 or as soon thereafter as is
practicable.
Pursuant to Rule 460 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Securities Act"), we, as representative
of the several Underwriters, wish to advise you that in connection with the
above-captioned Registration Statement, copies of the Preliminary Prospectus
dated February 3, 2005 were distributed as follows:
<TABLE>
<CAPTION>
Underwriter Date(s) Copies
----------- ------- ------
<S> <C> <C>
Joseph Gunnar & Co., LLC 02.04.05 - 02.05.05 550
LaSalle St. Securities Corp. 02.04.05 - 02.07.05 300
Newbridge Securities Corporation 02.04.05 - 02.07.05 250
----
Total: 1,100
</TABLE>
In accordance with Rule 461 of the General Rules and Regulations under the
Securities Act, we hereby join in the request of Tarpon Industries, Inc. to
accelerate the above-captioned Registration Statement, relating to the offering
of up to 3,277,500 common shares, no par value, of Tarpon Industries, Inc. in
its initial pubic offering and 758,800 common shares in a subsequent re-sale of
common shares by selling shareholders, so that it will become effective at 10:00
a.m. Eastern time on February 14, 2005 or as soon thereafter as is practicable.
The underwriters acknowledge that (1) 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, (2) the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing
<PAGE>
effective, does not relieve the underwriters from their full responsibility for
the adequacy and accuracy of the disclosure in the filing, and (3) the
underwriters 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.
Very truly yours,
JOSEPH GUNNAR & CO, LLC
REPRESENTATIVE OF THE
SEVERAL UNDERWRITERS
By: /s/ STEPHAN A. STEIN
-------------------------------------
Stephan A. Stein
Its: Chief Operating Officer
--------------------------
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