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SEC Company Response from VeriFone Holdings, Inc. (CIK 0001312073) — Apr 29, 2005

VeriFone Holdings, Inc. (CIK 0001312073)
Date: April 29, 2005 · CIK: 0001312073 · Accession: 0001104659-05-019440

AI Filing Summary & Sentiment

File numbers found in text: 333-121947

Date
April 29, 2005
Author
Director
Form
CORRESP
Company
VeriFone Holdings, Inc. (CIK 0001312073)

Letter

Securities and Exchange Commission Division of Corporation Finance Re: VeriFone Holdings, Inc. Registration Statement on Form S-1 File No. 333-121947

Dear Ms. Jacobs:

In accordance with Rule 461 under the Securities Act of 1933, we hereby request acceleration of the effective date of the Registration Statement on Form S-1 (No. 333-121947) (the “Registration Statement”) of VeriFone Holdings, Inc. (the “Registrant”). We respectfully request that the Registration Statement become effective as of 9:30 a.m., Washington, DC time, on April 29, 2005, or as soon as practicable thereafter. The Registrant is aware of its obligations under the Securities Act of 1933.

Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Sullivan & Cromwell LLP, by calling Scott D. Miller at (650) 461-5620. We also respectfully request that a copy of the written order from the Securities and Exchange Commission verifying the effective time and date of the Registration Statement be sent to our counsel, Sullivan & Cromwell LLP, Attention: Scott D. Miller, by facsimile to (650) 461-5700.

Please do not hesitate to call Mr. Miller at (650) 461-5620 if you have any questions regarding this request.

Very truly yours
/s/ Douglas G.
Bergeron

Show Raw Text
CORRESP
1
filename1.htm

VeriFone Holdings, Inc.

2099 Gateway Place, Suite 600

San Jose, California 95110

Telephone: (408) 232-7800

April 29,
2005

VIA
FACSIMILE

Securities and Exchange
Commission

450 Fifth Street, N.W.

Washington, DC  20549

Attn:                    Ms. Barbara
Jacobs

Assistant
Director

Division
of Corporation Finance

Re:                               VeriFone
Holdings, Inc.

Registration
Statement on Form S-1

File
No. 333-121947

Dear Ms. Jacobs:

In accordance with Rule 461 under the Securities
Act of 1933, we hereby request acceleration of the effective date of the
Registration Statement on Form S-1 (No. 333-121947) (the “Registration
Statement”) of VeriFone Holdings, Inc. (the “Registrant”).  We respectfully request that the Registration
Statement become effective as of 9:30 a.m., Washington, DC time, on April 29,
2005, or as soon as practicable thereafter.
The Registrant is aware of its obligations under the Securities Act of
1933.

Once the Registration Statement has been declared
effective, please orally confirm that event with our counsel, Sullivan &
Cromwell LLP, by calling Scott D. Miller at (650) 461-5620.  We also respectfully request that a copy of
the written order from the Securities and Exchange Commission verifying the
effective time and date of the Registration Statement be sent to our counsel, Sullivan
& Cromwell LLP, Attention:  Scott D.
Miller, by facsimile to (650) 461-5700.

Please do not hesitate to call Mr. Miller at (650) 461-5620
if you have any questions regarding this request.

  Very truly yours

  /s/ Douglas G.
  Bergeron

  Douglas G.
  Bergeron

  Chairman and
  Chief Executive Officer

cc:                                 Daniel
Lee

(Securities
and Exchange Commission)