| CONFIDENTIAL For Use of SEC Staff Only | ||||
| October 17, 2005 | ||||
| Electronic Filing Jeffrey Riedler Assistant Director Securities and Exchange Commission Division of Corporation Finance Mail Stop 0309 450 Fifth Street, N.W. Washington, DC 20549-0309 | ||||
| Re: | PXRE Group Ltd. Preliminary Proxy Statement on Schedule 14A (File No. 001-15259) |
Dear Mr. Riedler:
We are filing herewith the revised Proxy Statement on Schedule 14A and related proxy materials (the “Proxy Statement”) of PXRE Group Ltd., a Bermuda company (“PXRE” or the “Company”) (File No. 001-15259) relating to the Company’s proposed Special General Meeting of Shareholders (the “Meeting”) scheduled to be held on November 18, 2005.
We hereby acknowledge that:
| • | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | 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 |
| • | 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. |
If you require additional information concerning the Proxy Statement, please telephone the undersigned at (441) 278-3727.
Thank you for your attention to this matter.
| Very truly yours, | ||
| PXRE GROUP LTD. | ||
| By: | /s/ Robert P. Myron | |
| Name: Robert Myron Title: Senior Vice President and Treasurer | ||
| cc: | Greg Belliston, Esq. |
| SEC Division of Corporation Finance | |
| Mr. Jeffrey Radke Mr. Gerald Radke Bruce Byrnes, Esq. Mr. John Modin PXRE Group Ltd. | |
