Sichenzia Ross Friedman Ference LLP
1065 Avenue of the Americas New York NY 10018
Tel 212 930 9700 Fax 212 930 9725 www.srff.com
December 22, 2005
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mr. H. Roger Schwall
Ms. Mellissa Campbell Duru
Re:
Unico, Inc.
Definitive Proxy Statement
File No. 814-00669
Ladies and Gentlemen:
This firm represents Unico, Inc. (the “Company”) in the above-referenced matters. We hereby confirm on behalf of the Company, that:
The Company is responsible for the adequacy and accuracy of the disclosure in the subject 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.
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Should you have any further questions, please do not hesitate to contact the undersigned at (212) 930-9700.
Sincerely,
/s/ THOMAS A. ROSE
Thomas A. Rose
cc: Mr. Mark Lopez