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SEC Company Response from Cold Spring Capital Inc. (CIK 0001330446) — Nov 10, 2005

Cold Spring Capital Inc. (CIK 0001330446)
Date: Nov. 10, 2005 · CIK: 0001330446 · Accession: 0001047469-05-026593

AI Filing Summary & Sentiment

File numbers found in text: 333-125873

Date
November 9, 2005
Author
As representative of the several underwriters
Form
CORRESP
Company
Cold Spring Capital Inc. (CIK 0001330446)

Letter

Re: Cold Spring Capital Inc. S-1 Registration Statement, File No. 333-125873 -----------------------------------------------

<PAGE>

COLD SPRING CAPITAL INC. 51 Locust Avenue, Suite 302 New Canaan, Connecticut 06840

November 9, 2005

BY EDGAR AND FACSIMILE (202-772-9206) Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549 Attn: William A. Bennett

Ladies and Gentlemen:

The undersigned registrant hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, that the effective date of the above-referenced Registration Statement be accelerated so that it may become effective as of 16:00, eastern standard time, on November 10, 2005 or as soon thereafter as practicable.

Sincerely,

COLD SPRING CAPITAL INC.

By: /s/ Joseph S. Weingarten ------------------------------------ Name: Joseph S. Weingarten Title: President and Treasurer

<PAGE>

COLD SPRING CAPITAL INC. 51 Locust Avenue, Suite 302 New Canaan, Connecticut 06840

November 9, 2005

BY EDGAR AND FACSIMILE (202-772-9206) Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549 Attn: William A. Bennett

Re: Cold Spring Capital Inc. Registration Statement No. 333-125873 -------------------------------------

Ladies and Gentlemen:

In connection with the undersigned's request for acceleration of the effectiveness of the above-referenced Registration Statement pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned registrant hereby acknowledges that:

o should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

o the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

o the company may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

In addition, the undersigned registrant further acknowledges that the Division of Enforcement has access to all information provided to the staff of the Division of Corporation Finance in connection with the filing.

Sincerely,

COLD SPRING CAPITAL INC.

By: /s/ Joseph S. Weingarten ----------------------------------- Name: Joseph S. Weingarten Title: President and Treasurer

<PAGE>

DEUTSCHE BANK SECURITIES INC. 60 WALL STREET NEW YORK, NEW YORK 10005

November 9, 2005

BY EDGAR AND FACSIMILE ((202) 772-9206) Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: William A. Bennett

RE: COLD SPRING CAPITAL INC. REGISTRATION STATEMENT ON FORM S-1 FILE NO. 333-125873

Ladies and Gentlemen:

In connection with the above-captioned offering please be advised that, pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby join in the request of Cold Spring Capital Inc. that the effective date of the Registration Statement be accelerated so that the Registration Statement may become effective 16:00 EST on November 10, 2005, or as soon thereafter as practicable.

Sincerely,
DEUTSCHE BANK SECURITIES INC.
As representative of the several underwriters

Show Raw Text
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<PAGE>

                            COLD SPRING CAPITAL INC.
                           51 Locust Avenue, Suite 302
                          New Canaan, Connecticut 06840

                                November 9, 2005

BY EDGAR AND FACSIMILE (202-772-9206)
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C.  20549
Attn:  William A. Bennett

     Re:  Cold Spring Capital Inc.
          S-1 Registration Statement, File No. 333-125873
          -----------------------------------------------

Ladies and Gentlemen:

     The undersigned registrant hereby requests, pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended, that the effective
date of the above-referenced Registration Statement be accelerated so that it
may become effective as of 16:00, eastern standard time, on November 10, 2005
or as soon thereafter as practicable.

                                Sincerely,

                                COLD SPRING CAPITAL INC.

                                By: /s/ Joseph S. Weingarten
                                    ------------------------------------
                                    Name:  Joseph S. Weingarten
                                    Title: President and Treasurer

<PAGE>

                            COLD SPRING CAPITAL INC.
                           51 Locust Avenue, Suite 302
                          New Canaan, Connecticut 06840

                                November 9, 2005

BY EDGAR AND FACSIMILE (202-772-9206)
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C.  20549
Attn:  William A. Bennett

Re:  Cold Spring Capital Inc.
     Registration Statement No. 333-125873
     -------------------------------------

Ladies and Gentlemen:

     In connection with the undersigned's request for acceleration of the
effectiveness of the above-referenced Registration Statement pursuant to Rule
461 promulgated under the Securities Act of 1933, as amended, the undersigned
registrant hereby acknowledges that:

     o    should the Commission or the staff, acting pursuant to delegated
          authority, declare the filing effective, it does not foreclose the
          Commission from taking any action with respect to the filing;

     o    the action of the Commission or the staff, acting pursuant to
          delegated authority, in declaring the filing effective, does not
          relieve the company from its full responsibility for the adequacy and
          accuracy of the disclosure in the filing; and

     o    the company may not assert the declaration of effectiveness as a
          defense in any proceeding initiated by the Commission or any person
          under the federal securities law of the United States.

     In addition, the undersigned registrant further acknowledges that the
Division of Enforcement has access to all information provided to the staff of
the Division of Corporation Finance in connection with the filing.

                                         Sincerely,

                                         COLD SPRING CAPITAL INC.

                                         By: /s/ Joseph S. Weingarten
                                             -----------------------------------
                                             Name:  Joseph S. Weingarten
                                             Title: President and Treasurer

<PAGE>

                          DEUTSCHE BANK SECURITIES INC.
                                 60 WALL STREET
                            NEW YORK, NEW YORK 10005

November 9, 2005

BY EDGAR AND FACSIMILE ((202) 772-9206)
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attn:  William A. Bennett

RE: COLD SPRING CAPITAL INC.
    REGISTRATION STATEMENT ON FORM S-1
    FILE NO. 333-125873

Ladies and Gentlemen:

     In connection with the above-captioned offering please be advised that,
pursuant to Rule 461 under the Securities Act of 1933, as amended, the
undersigned hereby join in the request of Cold Spring Capital Inc. that the
effective date of the Registration Statement be accelerated so that the
Registration Statement may become effective 16:00 EST on November 10, 2005,
or as soon thereafter as practicable.

Sincerely,

DEUTSCHE BANK SECURITIES INC.
    As representative of the several underwriters

By: /s/ JEFFREY MORTARA
    -------------------------
    Name: Jeffrey Mortara
    Title: Managing Director

</TEXT>
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