OLSHAN
OLSHAN GRUNDMAN FROME ROSENZWEIG & WOLOSKY LLP
PARK AVENUE TOWER
65 EAST 55TH STREET
NEW YORK, NEW YORK 10022
TELEPHONE: 212.451.2300
September 13, 2005 FACSIMILE: 212.451.2222
WWW.OLSHANLAW.COM
DIRECT DIAL: 212-451-2333
EMAIL: SWOLOSKY@OLSHANLAW.COM
BY FEDERAL EXPRESS
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Nicholas P. Panos
Re: COMPUTER HORIZONS CORP. (THE "COMPANY")
PRELIMINARY SCHEDULE 14A FILED ON SEPTEMBER 9, 2005
FILED BY THE COMPUTER HORIZONS FULL VALUE COMMITTEE
FILE NO. 0-07282
Dear Mr. Panos:
We acknowledge receipt of the letter of comment dated September 12,
2005 from the Staff (the "Comment Letter") with regard to the above-referenced
matter. We have reviewed the Comment Letter with The Computer Horizons Full
Value Committee and provide the following supplemental response on its behalf.
Unless otherwise indicated, the page references below are to the marked version
of the enclosed paper copy of the Preliminary Schedule 14A filed on the date
hereof. Capitalized terms used herein and not separately defined have the
meanings given to them in the Preliminary Schedule 14A. Our responses are
numbered to correspond to your comments.
GENERAL
1. The disclosure has been revised to reflect the new meeting date and
meeting location. The disclosure has also been revised to reflect
the recent resignation of L. White Matthews. See Cover Letter and
pages 1, 7 to 8, 12 to 15 and Schedule II of Proxy Statement.
2. In light of the new meeting date, the Committee now intends to mail
proxy materials to all shareholders as of the September 12 record
date in one mailing and will not mail to security holders who hold
shares in "street name" as of a prior date. The disclosure has been
revised accordingly. See page 3 of Proxy Statement.
NEW JERSEY OFFICE
2001 ROUTE 46 / SUITE 202
PARSIPPANY, NEW JERSEY 07054
TELEPHONE: 973.335.7400
FACSIMILE: 973.335.8018
September 13, 2005
Page 2
BACKGROUND TO SOLICITATION
COMPUTER HORIZONS / ANALYSTS MERGER
3. The disclosure has been revised as requested. See page 5 of Proxy
Statement.
RESULTS OF SEPTEMBER 2 SPECIAL MEETING
4. The disclosure has been revised as requested. See page 7 of Proxy
Statement.
PROPOSAL NO. 3 - PROPOSAL TO ELECT THE NOMINEES
CHANGE OF CONTROL PROVISIONS
5. The disclosure has been revised as requested. See page 20 of Proxy
Statement.
* * * * *
The Staff is invited to contact the undersigned with any comments or
questions it may have. We would appreciate your prompt advice as to whether the
Staff has any further comments.
Very truly yours,
/s/ Steven Wolosky
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Steven Wolosky
Enclosures
cc: Eric Rosenfeld
Alan Bazaar
