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SEC Comment Letter for New Skies Satellites B.V. (CIK 0001313981) — Jun 9, 2005

New Skies Satellites B.V. (CIK 0001313981)
Date: June 9, 2005 · CIK: 0001313981 · Accession: 0000000000-05-028702

AI Filing Summary & Sentiment

File numbers found in text: 333-123420

Date
June 6, 2005
Author
Larry Spirgel
Form
UPLOAD
Company
New Skies Satellites B.V. (CIK 0001313981)

Letter

Mail Stop 0407 June 6, 2005 Daniel S. Goldberg Chief Executive Officer New Skies Satellites B.V. c/o CT Corporation System 111 Eighth Avenue New York, NY 10011

RE: New Skies Satellites B.V. Amendment No. 1 to Form S-4 Filed on May 27, 2005 File No. 333-123420

Dear Mr. Goldberg:

We have reviewed the amendment to your Form S-4 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.

1. Please advise us in your response letter whether New Skies Satellites N.V. plans to file its Form 20-F for the fiscal year ended December 31, 2004, and, if it does not plan do so, tell us how and when it intends to address this filing obligation under the Securities Exchange Act. We note an earlier comment letter response in which you indicated that New Skies Satellites N.V. planned to file a no-action letter requesting suspension of its Section 13 reporting obligation. 2. Please amend your Form S-4 to include the signature of your authorized representative in the United States. See Signatures Instruction 1 to Form S-4.

* * * *

As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Act of 1933 and that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

You may contact Cheryl Grant, Staff Attorney, at (202) 551- 3359, or me, at (202) 551-3810, with any questions.

Sincerely,
Larry Spirgel
Assistant Director

Show Raw Text
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<TEXT>

Mail Stop 0407

      June 6, 2005

Daniel S. Goldberg
Chief Executive Officer
New Skies Satellites B.V.
c/o CT Corporation System
111 Eighth Avenue
New York, NY  10011

	RE:  	New Skies Satellites B.V.
      Amendment No. 1 to Form S-4
      Filed on May 27, 2005
      File No. 333-123420

Dear Mr. Goldberg:

      We have reviewed the amendment to your Form S-4 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.

1. Please advise us in your response letter whether New Skies
Satellites N.V. plans to file its Form 20-F for the fiscal year
ended
December 31, 2004, and, if it does not plan do so, tell us how and
when it intends to address this filing obligation under the
Securities Exchange Act.  We note an earlier comment letter
response
in which you indicated that New Skies Satellites N.V. planned to
file
a no-action letter requesting suspension of its Section 13
reporting
obligation.
2. Please amend your Form S-4 to include the signature of your
authorized representative in the United States.  See Signatures
Instruction 1 to Form S-4.

*	*	*	*

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	You may contact Cheryl Grant, Staff Attorney, at (202) 551-
3359,
or me, at (202) 551-3810, with any questions.

								Sincerely,

								Larry Spirgel
								Assistant Director

cc:	via facsimile (212) 455-2502
      Rise Norman, Esq.
	Simpson, Thatcher & Bartlett LLP
Mr. Goldberg
New Skies Satellites B.V.
June 6, 2005
Page 2

</TEXT>
</DOCUMENT>