American Racing Capital, Inc.
P.O. Box 22002
San Diego, CA 92192
(800) 230-7132
August 13, 2007
U.S. Securities & Exchange Commission
100 F Street NE
Washington, D.C. 20549
Re: | American Racing Capital, Inc. |
| File No. 333-142381 |
Dear Sir/Madam:
Request is hereby made for the acceleration of the effective date of our Registration Statement on Form SB-2, File No. 333-142381, to 5:00 P.M. Eastern Standard Time on August 13, 2007, or as soon as practicable thereafter.
We are also aware that:
• Should the Commission or the staff, acting pursuant to a 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 a 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;
• 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 law of the Untied States.
Very truly yours,
AMERICAN RACING CAPITAL, INC.
/s/ A. Robert A. Kovelski
PRESIDENT AND CEO