SEC Company Response from Avicena Group, Inc. (CIK 0001317092) — Nov 14, 2005
Avicena Group, Inc. (CIK 0001317092)
Date: Nov. 14, 2005 · CIK: 0001317092 · Accession: 0001193125-05-224187
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File numbers found in text: 333-129536
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CORRESP 1 filename1.htm Effected date Acceleration Request AVICENA GROUP, INC. 228 Hamilton Avenue, Third Floor Palo Alto, California 94301 (415) 397-2898 November 11, 2005 Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Mail Stop 3561 Washington, DC 20549 Attn: Samuel Thomas Kluck, III VIA FACSIMILE AND EDGAR Re: Avicena Group, Inc. Acceleration Request for Registration Statement on Form SB-2 File No. 333-129536 Acceleration Request for Form 8-A Ladies and Gentlemen: In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Avicena Group, Inc. (the “Registrant”) hereby requests that the effective date for the Registration Statements and Form 8-A referred to above be accelerated to 4:00 p.m., eastern time, on November 14, 2005, or as soon as practicable thereafter. In making its request, the Registrant acknowledges that: • should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, such action does not foreclose the Commission from taking any action with respect to the Registration Statement; • the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and • the Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Very truly yours, Avicena Group, Inc. /s/ Belinda Tsao Nivaggioli Belinda Tsao Nivaggioli Chief Executive Officer