SEC Company Response from INTERNATIONAL SHIPPING ENTERPRISES, INC. (CIK 0001305220) — Dec 10, 2004
INTERNATIONAL SHIPPING ENTERPRISES, INC. (CIK 0001305220)
Date: Dec. 10, 2004 · CIK: 0001305220 · Accession: 0001047469-04-036815
AI Filing Summary & Sentiment
File numbers found in text: 000-51047, 333-119719
Letter
VIA EDGAR AND TELECOPY—202-942-9516 Mr. John Reynolds United States Securities and VIA EDGAR AND TELECOPY—202-942-9516 Mr. John Reynolds United States Securities and Attention: Division of Corporate Finance VIA EDGAR AND TELECOPY—202-942-9516 Mr. John Reynolds Washington, D.C. 20549-0405 RE:International Shipping Enterprises, Inc. (the "Company") Registration Statement on Form S-1 originally filed October 13, 2004 (File No. 333-119719) (the "Registration Statement")
Dear Mr. Reynolds:
In connection with the Registration Statement on Form S-1 of International Shipping Enterprises, Inc., the undersigned, which is acting as the representative of the underwriters of the offering, hereby requests acceleration of the effective date and time of the Registration Statement to 3:00 P.M., Friday, December 10, 2004 or as soon thereafter as practicable, pursuant to Rule 461 of the Securities Act of 1933.
Very truly yours,
SUNRISE SECURITIES CORP.
By:
/s/ NATHAN LOW Nathan Low
President
SUNRISE SECURITIES CORP.
641 Lexington Avenue
25th Floor
New York, New York 10022
December 10, 2004
VIA EDGAR AND TELECOPY Mr. John D. Reynolds
United States Securities and
Exchange Commission
Mail Stop 05-11, 450 Fifth Street, N.W.
Washington, D.C. 20549
RE:International Shipping Enterprises, Inc. (the "Company")
Registration Statement on Form S-1 originally filed October 13, 2004
(File No. 333-119719) (the "Registration Statement")
Ladies and Gentlemen:
In accordance with the provisions of Rule 460 under the Securities Act of 1933, the undersigned, as representative of the underwriters of the proposed offering of securities of International Shipping Enterprises, Inc., hereby advises that copies of the Preliminary Prospectus, dated October 13, 2004, were distributed on or about October 13, 2004, as follows:
to individual investors;
to NASD members (which included 10 prospective underwriters and selected dealers); and
to institutions.
The undersigned has been informed by the participating dealers that, in accordance with Rule 15c2-8 under the Securities Exchange Act of 1934, copies of the Preliminary Prospectus, dated October 13, 2004, have been distributed to all persons to whom it is expected that confirmations of sale will be sent; and we have likewise so distributed copies to all customers of ours. We have adequate equity to underwrite a "firm commitment" offering.
Very truly yours,
SUNRISE SECURITIES CORP.
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International Shipping Enterprises, Inc.
1225 Franklin Avenue
Garden City, New York 11530
December
10, 2004
VIA EDGAR AND TELECOPY—202-942-9516
Mr. John Reynolds
United States Securities and
Exchange Commission
Mail Stop 05-11, 450 Fifth Street, N.W.
Washington, D.C. 20549-0405
RE:International
Shipping Enterprises, Inc.
Registration Statement on Form S-1
Registration No. 333-119719
Request for Acceleration of Effectiveness
Ladies
and Gentlemen:
International
Shipping Enterprises, Inc. (the "Company") respectfully requests, pursuant to Rule 461 under the Securities Act of 1933, as amended (the "Act"), that the
Securities and Exchange Commission (the "Commission") accelerate the effective date of the above-referenced Registration Statement so that it may become effective at 3:00 p.m., Eastern Standard
Time, December 10, 2004, or as soon thereafter as practicable. The Company would also appreciate telephone notice of such effectiveness to Scott M. Miller at (212) 269-1400.
In
connection with the Company's request for acceleration of effectiveness of the above-referenced Registration Statement, the Company acknowledges the following:
(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 effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and
(3) The
Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.
Very truly yours,
INTERNATIONAL SHIPPING ENTERPRISES, INC.
By:
/s/ ANGELIKI FRANGOU Angeliki Frangou, Chairman, Chief
Executive Officer and President
International Shipping Enterprises, Inc.
1225 Franklin Avenue
Garden City, New York 11530
December
10, 2004
VIA EDGAR AND TELECOPY—202-942-9516
Mr. John Reynolds
United States Securities and
Exchange Commission
Mail Stop 05-11, 450 Fifth Street, N.W.
Washington, D.C. 20549-0405
Attention: Division
of Corporate Finance
Re:International
Shipping Enterprises, Inc.
Registration Statement on Form 8-A
Registration No. 000-51047
Request for Acceleration of Effectiveness
Ladies
and Gentlemen:
On
November 24, 2004, the undersigned Registrant filed a Form 8-A under the Securities Act of 1934, as amended to qualify the proposed listing of its Units,
Common Stock and Warrants, which Units, Common Stock and Warrants are being offered to the public pursuant to a Registration Statement on Form S-1 (Registration
No. 333-119719) and the amendments thereto, under the Securities Act of 1933, as amended (the "Act").
International
Shipping Enterprises, Inc., hereby respectfully requests, pursuant to Rule 461 under Act, that the Securities and Exchange Commission accelerate the effective
date of the above-referenced Registration Statement simultaneously with the effectiveness of its Registration Statement No. 333-119719, for which acceleration has been requested to
3:00 p.m. Eastern Standard Time on December 10, 2004, or as soon thereafter as practicable.
Very truly yours,
INTERNATIONAL SHIPPING ENTERPRISES, INC.
By:
/s/ ANGELIKI FRANGOU Angeliki Frangou, Chairman, Chief
Executive Officer and President
SUNRISE SECURITIES CORP.
641 Lexington Avenue
25th Floor
New York, New York 10022
December
10, 2004
VIA EDGAR AND TELECOPY—202-942-9516
Mr. John Reynolds
Unites States Securities and
Exchange Commission
Mail Stop 05-11, 450 Fifth Street, N.W.
Washington, D.C. 20549-0405
RE:International Shipping Enterprises, Inc. (the "Company")
Registration Statement on Form S-1 originally filed October 13, 2004
(File No. 333-119719) (the "Registration Statement")
Dear Mr. Reynolds:
In
connection with the Registration Statement on Form S-1 of International Shipping Enterprises, Inc., the undersigned, which is acting as the representative of
the underwriters of the offering, hereby requests acceleration of the effective date and time of the Registration Statement to 3:00 P.M., Friday, December 10, 2004 or as soon thereafter
as practicable, pursuant to Rule 461 of the Securities Act of 1933.
Very truly yours,
SUNRISE SECURITIES CORP.
By:
/s/ NATHAN LOW Nathan Low
President
SUNRISE SECURITIES CORP.
641 Lexington Avenue
25th Floor
New York, New York 10022
December
10, 2004
VIA EDGAR AND TELECOPY
Mr. John D. Reynolds
United States Securities and
Exchange Commission
Mail Stop 05-11, 450 Fifth Street, N.W.
Washington, D.C. 20549
RE:International Shipping Enterprises, Inc. (the "Company")
Registration Statement on Form S-1 originally filed October 13, 2004
(File No. 333-119719) (the "Registration Statement")
Ladies and Gentlemen:
In
accordance with the provisions of Rule 460 under the Securities Act of 1933, the undersigned, as representative of the underwriters of the proposed offering of securities of
International Shipping Enterprises, Inc., hereby advises that copies of the Preliminary Prospectus, dated October 13, 2004, were distributed on or about October 13, 2004, as
follows:
200
to individual investors;
350
to NASD members (which included 10 prospective underwriters and selected dealers); and
650
to institutions.
The
undersigned has been informed by the participating dealers that, in accordance with Rule 15c2-8 under the Securities Exchange Act of 1934, copies of the
Preliminary Prospectus, dated October 13, 2004, have been distributed to all persons to whom it is expected that confirmations of sale will be sent; and we have likewise so distributed copies
to all customers of ours. We have adequate equity to underwrite a "firm commitment" offering.
Very truly yours,
SUNRISE SECURITIES CORP.
By:
/s/ NATHAN LOW Nathan Low
President