DEWEY BALLANTINE LLP
1301 AVENUE OF THE AMERICAS
NEW YORK, NEW YORK 10019-6092
TEL 212 259-8000 FAX 212 259-6333
October 21, 2005
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Amendment No. 1 to the Platinum Underwriters Finance and Platinum Underwriters Holdings
Registration Statement on Form S-4
Dear Ladies and Gentlemen:
On behalf of our clients, Platinum Underwriters Finance, Inc., a Delaware corporation (the “Company”), and Platinum Underwriters Holdings, Ltd., a Bermuda corporation (the “Guarantor”), we hereby submit for filing under the Securities Act of 1933, as amended (the “Securities Act”), by electronic submission pursuant to the EDGAR program of the Securities and Exchange Commission (the “Commission”), Amendment No. 1 to the Company’s and the Guarantor’s Registration Statement on Form S-4 and exhibits, for registration under the Securities Act of securities in connection with an exchange offer described in the Amendment No. 1 to the Registration Statement pursuant to the Commission's Exxon Capital line of No Action Letters.
If you have any questions concerning the foregoing, please contact me at (212) 259-6680 (or email at jfreedman@dbllp.com).
Very truly yours, | |||||
/s/ Jonathan L. Freedman Jonathan L. Freedman |
Enclosure
cc: Michael E. Lombardozzi
Executive Vice President, General Counsel
& Chief Administrative Officer
Platinum Underwriters Holdings, Ltd.