| 949-476-1180 3001 Daimler Street Santa Ana, California 92705-5812 www.sTec-inc.com |
Via EDGAR
June 24, 2013
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-3628
| Attn: | Nicholas P. Panos, Senior Special Counsel, Office of Mergers and Acquisitions |
| Re: | sTec, Inc. Definitive Additional Materials on Schedule 14A Filed June 10, 2013 File No. 000-31623 |
Dear Mr. Panos:
Reference is made to your letter, dated June 12, 2013, regarding the Definitive Additional Materials on Schedule 14A filed by sTec, Inc. (“sTec”) with the U.S. Securities and Exchange Commission (the “Commission”).
Per your request, sTec hereby acknowledges that:
| • | it 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 |
| • | it 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 have any questions, please do not hesitate to call me at (949) 476-1180.
Sincerely,
/s/ Robert M. Saman
Robert M. Saman
Chief Legal Officer and General Counsel
Mr. Nicholas P. Panos
June 24, 2013
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| cc: | Gabriel Eckstein, Staff Attorney U.S. Securities and Exchange Commission Mark Moshayedi, President and Chief Executive Officer sTec, Inc. Michelle A. Hodges James J. Moloney David C. Lee Gibson, Dunn & Crutcher LLP |