Burhmann US, Inc.
Hoogoorddreef 62
1101 BE Amsterdam ZO
The Netherlands
August 1, 2005
H. Roger Schwall, Esq.
Assistant Director
Office of Natural Resources
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0405
United States of America
Re: Buhrmann US Inc.
Registration Statement on Form F-4; Filing No. 333-123952
Dear Mr. Schwall:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, on behalf of Buhrmann US Inc. and its co-registrants (the “Registrants”), I hereby request that the effective date of to the Registrants’ Registration Statement on Form F-4, as amended, be accelerated to 10:00 a.m., Eastern standard time, or as soon as practical thereafter, on August 3, 2005.
The Registrants acknowledge the following:
• should the Commission or the Staff, acting pursuant to 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 delegated authority, in declaring the filing effective, does not relieve the Registrants from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
• the Registrants may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
| Very truly yours, |
| |
| BUHRMANN US INC. |
| |
| By: | /s/ Heidi van der Kooij |
| | Name: Heidi van der Kooij |
| | Title: Secretary |
cc: Alexander F. Cohen, Latham & Watkins LLP
David Hong, Latham & Watkins LLP