SecProbe.io

CORRESP
1
filename1.htm

                              December
        19,
        2005

      VIA
        EDGAR

      Securities
        and Exchange Commission

      100
        F
        Street, N.W.

      Washington,
        DC 20549

      Attention:
        Mr. John Reynolds

      Re:  Highbury
        Financial Inc.

          Registration
        Statement on Form S-1 (File No. 333-127272)

      Dear
        Mr.
        Reynolds:

      In
        connection with the above-referenced Registration Statement, on behalf of
        the
        Representative of the proposed Underwriters, we wish to advise you that the
        Representative requests that the above-referenced Registration Statement
        be
        accelerated so that the same will become effective at 4:30 New York City
        time,
        on December 21, 2005, or as soon thereafter as practicable.

      In
        making
        the foregoing request, we confirm that we are aware of our obligations under
        Rule 460 under the Securities Act of 1933, as amended, and that in compliance
        therewith, we have taken reasonable steps to make the information contained
        in
        the Registration Statement conveniently available to underwriters and dealers
        who will be invited to participate in the distribution of the securities
        registered thereunder. We further confirm that we have and will comply with
        Rule
        15c2-8 under the Securities Exchange Act of 1934, as amended, with respect
        to
        the distribution of Prospectuses. We have been informed by the other
        underwriters and dealers participating in the distribution of this offering
        that
        such persons have and will comply with Rule 15c2-8 with respect to the
        distribution of Prospectuses. Between October 28, 2005 and December 19, 2005
        (48
        business hours before proposed effectiveness of the Registration Statement)
        we
        distributed (i) 183 copies of the Preliminary Prospectus dated October 28,
        2005,
        of which no copies were distributed to other underwriters and approximately
        183
        to investors, including individuals and institutions, and (ii) 266 copies
        of the
        Preliminary Prospectus dated December 6, 2005, of which no copies were
        distributed to other underwriters and approximately 266 to investors, including
        individuals and institutions. Copies of the Preliminary Prospectus were
        available to anyone requesting the same at the offices of the underwriters.
        The
        underwriting arrangements have been described to the National Association
        of
        Securities Dealers, Inc., and the Association has advised us that they have
        no
        objection to the underwriters’ compensation and other underwriting
        arrangements.

        Securities
          and Exchange Commission

        December
          19, 2005

        Page
          2

      If
        you
        have questions or comments regarding this request, please call Kenneth L.
        Guernsey, Cooley Godward LLP at (415) 693-2000.

               Sincerely,

               ThinkEquity Partners LLC

               By: /s/
                Benjamin J. Davey

               Name: Benjamin
                J. Davey

               Title: Managing
                Director, Head of Syndicate