May 2, 2005
VIA EDGAR TRANSMISSION
Mr. Mark Webb
Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street
Washington, D.C. 20549
Re: | Lazard Ltd — |
Registration Statement on Form S-1 relating to the |
initial public offering of equity security units of Lazard Ltd |
Ladies and Gentlemen:
On behalf of Lazard Ltd, an exempted Bermuda limited company (the “Company”), and Lazard Group Finance LLC, a Delaware limited liability company (together with the Company, the “Registrants”), submitted for filing under the Securities Act of 1933, as amended, is Amendment No. 2 to Registrants’ Registration Statement on Form S-1 (the “Registration Statement”), relating to a proposed initial public offering of equity security units by the Company.
Please note that the filing fee for the Registration Statement was previously paid upon the initial filing of the Registration Statement.
Securities and Exchange Commission
May 2, 2005
Page 2
If you have any questions regarding this filing, please contact the undersigned at (212) 403-1340, or
Benjamin D. Fackler, Esq. at (212) 403-1395, both of this office, as counsel to the Company.
Very truly yours,
/s/ Sarah A. Lewis
Sarah A. Lewis, Esq.
cc: Scott D. Hoffman, Esq. (Lazard Ltd)