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SEC Company Response from Avicena Group, Inc. (CIK 0001317092) — Nov 14, 2005

Avicena Group, Inc. (CIK 0001317092)
Date: Nov. 14, 2005 · CIK: 0001317092 · Accession: 0001193125-05-225491

AI Filing Summary & Sentiment

File numbers found in text: 333-129536

Date
November 14, 2005
Author
/s/ Jeffrey A. Schumacher
Form
CORRESP
Company
Avicena Group, Inc. (CIK 0001317092)

Letter

Securities and Exchange Commission Division of Corporation Finance VIA EDGAR Re: Avicena Group, Inc. (the “Registrant”) Amendment No. 1 to Registration Statement on Form SB-2 File # 333-129536 (“Amendment No. 1”)

Dear Mr. Kluck:

In response to your inquiry regarding the subsection entitled “Promissory Notes” of Item 26 of Part II of Registrant’s Amendment No. 1, the Registrant hereby supplementally advises the Commission that the issuance of each promissory note referenced in such subsection was exempt from registration pursuant to Section 4(2) of the Securities Act, as further described in the subsection entitled “Bases for Exemption” of Item 26 of Part II of Amendment No. 1.

If you have any comments or questions or if we can facilitate your review in any matter, please do not hesitate to contact the undersigned (312-207-6414) or Karla Rachwalski of this office (312-207-3922).

We thank you for your time and attention to this matter.

Very truly yours,
/s/ Jeffrey A. Schumacher

Show Raw Text
CORRESP
1
filename1.htm

Correspondence Letter

 Sachnoff & Weaver, Ltd.

 10 South Wacker Drive

 Chicago, Illinois 60606-7507

 t 312.207.1000    f 312.207.6400

 www.sachnoff.com

 [Logo of Sachnoff & Weaver appears here]

 November 14, 2005

 Samuel Thomas Kluck II

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

 Mail Stop 3561

 Washington, D.C. 20549

 VIA EDGAR

Re:
Avicena Group, Inc. (the “Registrant”)

 Amendment No. 1 to Registration Statement on Form SB-2

 File # 333-129536 (“Amendment No. 1”)

 Dear Mr. Kluck:

 In response to your inquiry regarding the subsection entitled
“Promissory Notes” of Item 26 of Part II of Registrant’s Amendment No. 1, the Registrant hereby supplementally advises the Commission that the issuance of each promissory note referenced in such subsection was exempt from
registration pursuant to Section 4(2) of the Securities Act, as further described in the subsection entitled “Bases for Exemption” of Item 26 of Part II of Amendment No. 1.

 If you have any comments or questions or if we can facilitate your review in
any matter, please do not hesitate to contact the undersigned (312-207-6414) or Karla Rachwalski of this office (312-207-3922).

 We thank you for your time and attention to this matter.

 Very truly yours,

 /s/ Jeffrey A. Schumacher

 Jeffrey A. Schumacher

 for SACHNOFF & WEAVER, LTD.

 JAS/kjr

cc:
Avicena Group, Inc.