SEC Company Response from Columbia Equity Trust, Inc. (CIK 0001316710) — Jun 2, 2005
Columbia Equity Trust, Inc. (CIK 0001316710)
Date: June 2, 2005 · CIK: 0001316710 · Accession: 0000950133-05-002519
AI Filing Summary & Sentiment
File numbers found in text: 333-122644
Letter
May 5, 2005 VIA OVERNIGHT DELIVERY Mr. Jeffrey Shady Mailstop 0409 U.S. Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549-0409
Re: Columbia Equity Trust, Inc. Registration Statement No. 333-122644
Dear Mr. Shady:
Reference is made to Amendment No. 1 ("Amendment No. 1") to the Registration Statement on Form S-11 filed by Columbia Equity Trust, Inc. (the "Company") with the Securities and Exchange Commission (the "Commission") on April 27, 2005. Reference is also made to that certain letter, dated April 27, 2005 (the "Response Letter"), from David C. Wright of Hunton & Williams LLP to Ms. Karen J. Garnett of the Commission, which Response Letter responded to certain comments of the staff of the Commission's Division of Corporation Finance set forth in a letter, dated March 10, 2005, from Ms. Garnett to Oliver T. Carr, III of the Company, and which Response Letter was transmitted to the Commission simultaneously with the filing of Amendment No. 1.
In the Response Letter, the Company agreed to provide supplementally certain materials to the Commission. Enclosed please find:
(1) A redweld folder containing a citation index for the market section source data and copies of market and industry data cited or relied on in Amendment No. 1 (Comments 3 and 59). In each case, we have endeavored to appropriately mark, date and reference the page numbers on which the information is cited.
<PAGE> Mr. Jeffrey Shady May 5, 2005 Page 2
(2) Attached hereto as Exhibit A, a copy of the Net Roadshow, Inc. Standard Service Agreement (Comment 79).
(3) Attached hereto as Exhibit B, a schedule of the Company's significant test calculations required by Item 3-14 of Regulation S-X, as referenced in the Response Letter (Company's response to Comment 92).
(4) Attached hereto as Exhibit C, a schedule showing the Company's calculation of compliance with Item 3-09 of Regulation S-X, as referenced in the Response Letter (Company's response to Comment 93).
(5) Attached hereto as Exhibit D, the form of opinion of Venable LLP opining as to the validity of the securities, which remains subject to change (Comment 95).
(6) Attached hereto as Exhibit E, the form of opinion of Hunton & Williams LLP opining as to certain tax matters, which remains subject to change (Comment 95).
As soon as practicable, we will provide to you supplementally under separate cover copies of market and industry data relied upon for the six citations presently unsupported in the enclosed redweld folder, as well as any graphics, maps, photographs and related captions or other artwork that the Company intends to use in the prospectus (Comment 4) and copies of the directed share program materials (Comment 75).
Please call David Wright ((804) 788-8638), Greg Cope ((804) 788-8388) or me with any questions.
Sincerely,
/s/ Christopher C. Green
Show Raw Text
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HUNTON & Williams LLP
RIVERFRONT PLAZA, EAST TOWER
951 EAST BYRD STREET
RICHMOND, VIRGINIA 23219-4074
Tel 804 - 788 - 8200
Fax 804 - 788 - 8218
May 5, 2005
VIA OVERNIGHT DELIVERY
Mr. Jeffrey Shady
Mailstop 0409
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0409
Re: Columbia Equity Trust, Inc.
Registration Statement No. 333-122644
Dear Mr. Shady:
Reference is made to Amendment No. 1 ("Amendment No. 1") to the Registration
Statement on Form S-11 filed by Columbia Equity Trust, Inc. (the "Company") with
the Securities and Exchange Commission (the "Commission") on April 27, 2005.
Reference is also made to that certain letter, dated April 27, 2005 (the
"Response Letter"), from David C. Wright of Hunton & Williams LLP to Ms. Karen
J. Garnett of the Commission, which Response Letter responded to certain
comments of the staff of the Commission's Division of Corporation Finance set
forth in a letter, dated March 10, 2005, from Ms. Garnett to Oliver T. Carr, III
of the Company, and which Response Letter was transmitted to the Commission
simultaneously with the filing of Amendment No. 1.
In the Response Letter, the Company agreed to provide supplementally certain
materials to the Commission. Enclosed please find:
(1) A redweld folder containing a citation index for the market section source
data and copies of market and industry data cited or relied on in Amendment No.
1 (Comments 3 and 59). In each case, we have endeavored to appropriately mark,
date and reference the page numbers on which the information is cited.
<PAGE>
Mr. Jeffrey Shady
May 5, 2005
Page 2
(2) Attached hereto as Exhibit A, a copy of the Net Roadshow, Inc. Standard
Service Agreement (Comment 79).
(3) Attached hereto as Exhibit B, a schedule of the Company's significant test
calculations required by Item 3-14 of Regulation S-X, as referenced in the
Response Letter (Company's response to Comment 92).
(4) Attached hereto as Exhibit C, a schedule showing the Company's calculation
of compliance with Item 3-09 of Regulation S-X, as referenced in the Response
Letter (Company's response to Comment 93).
(5) Attached hereto as Exhibit D, the form of opinion of Venable LLP opining as
to the validity of the securities, which remains subject to change (Comment 95).
(6) Attached hereto as Exhibit E, the form of opinion of Hunton & Williams LLP
opining as to certain tax matters, which remains subject to change (Comment 95).
As soon as practicable, we will provide to you supplementally under separate
cover copies of market and industry data relied upon for the six citations
presently unsupported in the enclosed redweld folder, as well as any graphics,
maps, photographs and related captions or other artwork that the Company intends
to use in the prospectus (Comment 4) and copies of the directed share program
materials (Comment 75).
Please call David Wright ((804) 788-8638), Greg Cope ((804) 788-8388) or me with
any questions.
Sincerely,
/s/ Christopher C. Green
Christopher C. Green
Direct Dial: 804-788-8309
EMAIL: cgreen@hunton.com
File No: 53582.20
Enclosures
<PAGE>
Exhibit A
(Net Roadshow, Inc. Standard Service Agreement)
<PAGE>
Exhibit B
(Schedule of Significant Test Calculations)
<PAGE>
Exhibit C
(Schedule Showing Compliance With Item 3-09 of Regulation S-X)
<PAGE>
Exhibit D
(Form of Opinion of Venable LLP)
<PAGE>
Exhibit E
(Form of Opinion of Hunton & Williams LLP)
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