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SEC Company Response from TriView Global Fund, LLC (CIK 0001305631) — Sep 29, 2005

TriView Global Fund, LLC (CIK 0001305631)
Date: Sept. 29, 2005 · CIK: 0001305631 · Accession: 0001305631-05-000008

AI Filing Summary & Sentiment

File numbers found in text: 333-119655

Date
September 28, 2005
Author
Assistant Director
Form
CORRESP
Company
TriView Global Fund, LLC (CIK 0001305631)

Letter

(305) 754-3603 facsimile (305) 754-2668 wscott@wscottlaw.com September 28, 2005 Ms. Karen Garnett Assistant Director U.S. Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549

Re: TriView Global Fund, LLC (the "Registrant" and the "Fund") Registration Statement on Form S-1, Pre-effective Amendment No. 5 File No. 333-119655

Dear Ms. Garnett,

We have reproduced your letter to the Registrant of September 9, 2005, and have supplied its response immediately following each of the comments. All changes are reflected in the Issuer's Registration Statement, Pre-effective Amendment No. 5 filed herewith.

We are available to amplify or clarify any response.

Very truly yours,
/s/ William S. Scott
William Sumner Scott
For the Firm

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                           THE SCOTT LAW FIRM, P.A.
                      940 Northeast 79th Street, Suite A
                             Miami, Florida  33138

                                (305) 754-3603
                           facsimile (305) 754-2668
                             wscott@wscottlaw.com

                                                September 28, 2005

Ms. Karen Garnett
Assistant Director
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Re:   TriView Global Fund, LLC (the "Registrant" and the "Fund")
      Registration Statement on Form S-1, Pre-effective Amendment No. 5
      File No. 333-119655

Dear Ms. Garnett,

      We have reproduced your letter to the Registrant of September 9,
2005, and have supplied its response immediately following each of the
comments.  All changes are reflected in the Issuer's Registration
Statement, Pre-effective Amendment No. 5 filed herewith.

      We are available to amplify or clarify any response.

                                                Very truly yours,

                                                /s/ William S. Scott
                                                William Sumner Scott
                                                For the Firm

WSS/lf

cc:   TriView Capital Management, Inc.
      Managing Member

<page>
                                UNITED STATES
                      SECURITIES AND EXCHANGE COMMISSION
                            WASHINGTON, D.C. 20549

DIVISION of
CORPORATION FINANCE

Mail Stop 4561

September 9, 2005

Michael Pacult
Managing Member
TriView Global Fund, LLC
5916 N. 300 West
Fremont, Indiana 46737

Re:    TriView Global Fund, LLC
       Amendment No. 4 to Form S-1
       Filed on August 31, 2005
       File No. 333-119655

Dear Mr. Pacult:

We have reviewed your amended filing and have the following comments.
Where indicated, we think you should revise your document in response
to these comments. If you disagree, we will consider your explanation
as to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation. In some of our
comments, we may ask you to provide us with supplemental information so
we may better understand your disclosure. After reviewing this
information, we may or may not raise additional comments.

For purposes of this comment letter, we refer to the pagination,
paragraphs, sentence and line numbers as displayed by the marked
courtesy copy version of your amended Form S-1 filed on August 31,
2005.

Break Even Analysis, page 15

1.      We note footnote 10 to your table indicates that you have
assumed an average 2% redemption fee for purposes of calculating the
referenced break even percentage. To the contrary, it does not appear
that you have assumed any redemption fee for the purposes of this
calculation in the table. Please revise to delete this statement from
footnote (10).

Response:      We have revised as follows:

(10) There is a redemption fee of 3% during the first four months of
investment, 2% the second four months and 1% the third four months.
There is no redemption fee after the first twelve months of investment.
You will be permitted to withdraw your subscriptions for five days
after submission to the managing member for acceptance.

2.      Refer to the line items that reflect break-even amounts at each
redemption amount within the first 12 months. Please revise the line
items in the left column to more clearly state that the break even
amounts represent income required during the first four months, the
second four months, and the third four months, respectively.

<page>

Response:      We have revised as follows:

Trading Income Required to Redeem one Unit at Initial Value after
twelve months (9)

Income as a % of Selling Price Per Unit with 0% redemption fee after
twelve months (10)

Redemption during first 4 months:  Income as a % of Selling Price Per
Unit with 3% redemption fee (11)

Redemption during second 4 months:  Income as a % of Selling Price Per
Unit with 2% redemption fee (12)

Redemption during third 4 months:  Income as a % of Selling Price Per
Unit with 1% redemption fee (13)

End of responses.
</TEXT>
</DOCUMENT>