CDSI HOLDINGS INC.
100 S.E. Second Street
Miami, Florida 33131
Phone #: 305-579-8000
September 30, 2011
VIA EDGAR
Mr. John Reynolds
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
| | RE: | CDSI Holdings Inc. (the "Company") Form PREM14C originally filed August 18, 2011 (File No. 000-22563) |
The Company hereby acknowledges the following:
(1) The Company is responsible for the adequacy and accuracy of the disclosure in the filing;
(2) Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
(3) The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
| | Very truly yours, | |
| | | | |
| | By: | /s/ J. Bryant Kirkland III | |
| | | Name: J. Bryant Kirkland III | |
| | | Title: Vice President, Chief Financial Office and Treasurer | |
| | | | |
