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SEC Company Response from BRC Group Holdings, Inc. (RILY, RILYG, RILYL, RILYN, RILYP, RILYT, RILYZ) (CIK 0001464790) (RILY) — Jul 17, 2009

BRC Group Holdings, Inc. (RILY, RILYG, RILYL, RILYN, RILYP, RILYT, RILYZ) (CIK 0001464790)
Date: July 17, 2009 · CIK: 0001464790 · Accession: 0001193125-09-150857

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File numbers found in text: 333-159644

Date
July 17, 2009
Author
Klein
Form
CORRESP
Company
BRC Group Holdings, Inc. (RILY, RILYG, RILYL, RILYN, RILYP, RILYT, RILYZ) (CIK 0001464790)

Letter

VIA EDGAR AND FACSIMILE United States Securities and Exchange Commission Washington, D.C. 20549 Attn: H. Christopher Owings, Assistant Director Re: Great American Group, Inc. Registration Statement on Form S-4 (File No. 333-159644)

Dear Mr. Owings:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the Registrant hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 5:00 p.m. on Friday, July 17, 2009, or as soon as thereafter practicable.

Please note that we acknowledge 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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Registrant may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
/s/ Mark D.
Klein

Show Raw Text
CORRESP
1
filename1.htm

Acceleration Request

 GREAT AMERICAN GROUP, INC.

 590 Madison Avenue

 New York, New York 10022

 July 17, 2009

 VIA EDGAR AND FACSIMILE

 United States Securities and Exchange Commission

 100
F Street

 Washington, D.C. 20549

Attn:
H. Christopher Owings, Assistant Director

Re:
Great American Group, Inc.

Registration Statement on Form S-4 (File No. 333-159644)

 Dear Mr.
Owings:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, the Registrant hereby requests acceleration of effectiveness of
the above referenced Registration Statement so that it will become effective at 5:00 p.m. on Friday, July 17, 2009, or as soon as thereafter practicable.

 Please note that we acknowledge 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 Registrant from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

 the Registrant may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United
States.

 Very truly yours,

 /s/ Mark D.
Klein

 Mark D. Klein

 Chief Executive Officer and Chief Financial Officer