SEC Company Response from AYTU BIOPHARMA, INC (AYTU) (CIK 0001385818) (AYTU) — May 8, 2007

AYTU BIOPHARMA, INC (AYTU) (CIK 0001385818)
Date: May 8, 2007 · CIK: 0001385818 · Accession: 0001079974-07-000296

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File numbers found in text: 333-139933

Date

May 8, 2007

Author

Wiegand, President

Form

CORRESP

Company

AYTU BIOPHARMA, INC (AYTU) (CIK 0001385818)

Letter

Request for Acceleration

Rosewind Corporation

WCR 18 E

Loveland, CO 80537

970-635-0346

May 8,

Mr. William Bennett, Staff Attorney

U.S. Securities and Exchange Commission

F Street, N. E.

Washington, D.C. 20549

VIA FAX: 202-772-9205 and EDGAR

Re: Rosewind Corporation

Form SB-2 Registration Statement

File No. 333-139933

Ladies and Gentlemen;

This request for acceleration hereby supersedes the request for acceleration previously filed on May 3rd. At this time, on behalf of the Company, we hereby request acceleration of the effective date of the Registration Statement pursuant to Rule 461 to Thursday, May 10, 2007 at 3 PM, Washington, D.C. local time, or as soon as practicable thereafter. In connection with this request, we represent the following:

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;

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

The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We confirm that we are aware of our responsibilities under the Securities Act and the Securities Exchange Act as they relate to the public offering of securities specified in the Registration Statement. Further, we understand that request for acceleration is a confirmation of the fact that we are aware of our responsibilities under the federal securities laws. If you have any additional questions, do not hesitate to contact me, James Wiegand at (970)635-0346. For accounting comments, please contact Rachel Boulds, HJ & Associates at 801-328-4408.

Rosewind Corporation

/s/ James Wiegand

James Wiegand, President

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CORRESP
1
filename1.htm

      Request for Acceleration

    Rosewind
      Corporation

    16200
      WCR 18 E

    Loveland,
      CO 80537

    970-635-0346

    May
      8,
      2007

    Mr.
      William Bennett, Staff Attorney

    U.S.
      Securities and Exchange
      Commission

    100
      F
      Street, N. E.

    Washington,
      D.C. 20549

        VIA
      FAX:
      202-772-9205 and EDGAR

        Re:      Rosewind
      Corporation

            Form
      SB-2
      Registration Statement

            File
      No.
      333-139933

    Ladies
      and Gentlemen;

      This
        request for acceleration hereby supersedes the request for acceleration
        previously filed on May 3rd.  At this time, on behalf of the Company, we
        hereby request acceleration of the effective date of the Registration Statement
        pursuant to Rule 461 to Thursday, May 10, 2007 at 3 PM, Washington, D.C.
        local
        time, or as soon as practicable thereafter. In connection with this request,
        we
        represent the following:

    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;

    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

    The
      Company may not assert staff comments and the declaration of effectiveness
      as a
      defense in any proceeding initiated by the Commission or any person under the
      federal securities laws of the United States.

    We
      confirm that we are aware of our responsibilities under the Securities Act
      and
      the Securities Exchange Act as they relate to the public offering of securities
      specified in the Registration Statement. Further, we understand that request
      for
      acceleration is a confirmation of the fact that we are aware of our
      responsibilities under the federal securities laws. If you have any additional
      questions, do not hesitate to contact me, James Wiegand at (970)635-0346. For
      accounting comments, please contact Rachel Boulds, HJ & Associates at
      801-328-4408.

    Rosewind
      Corporation

    /s/
      James Wiegand

    James
      Wiegand, President

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