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New Skies Satellites B.V.
Rooseveltplantsoen 4
2517 KR The Hague
The Netherlands
VIA FACSIMILE AND EDGAR
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
| | Re: | | New Skies Satellites B.V. Registration Statement on Form S-4 File No.: 333-123420
|
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the "Act"), the undersigned hereby requests that the effective date of the above-referenced Registration Statement on Form S-4, as amended, of New Skies Satellites B.V. (the "Company") be accelerated so that the Registration Statement may become effective at 2:00 p.m. EDT on June 8, 2005, or as soon as possible thereafter. In this regard, the Company is aware of its obligations under the Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed exchange offer specified in the above-referenced Registration Statement.
Pursuant to this request, the Company acknowledges that:
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- should the Securities and Exchange Commission (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;
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- the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
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- the Company may not assert this action 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, |
| | New Skies Satellites B.V. |
| | By: | /s/ THAI RUBIN |
| | | Name: Thai Rubin |
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New Skies Satellites B.V. Rooseveltplantsoen 4 2517 KR The Hague The Netherlands