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 (No. 333-123463) relating to the
initial public offering of equity security units of Lazard Ltd
Ladies and Gentlemen:
On behalf of Lazard Ltd, a Bermuda corporation (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. 1 to Registrants’ Registration Statement on Form S-1 (the “Registration Statement”), relating to a proposed initial public offering of equity security units of the Company.
Please note that the filing fee for the Registration Statement was previously paid upon the initial filing of the Registration Statement.
WACHTELL, LIPTON, ROSEN & KATZ
Securities and Exchange Commission
April 18, 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/ Kevin M. Costantino |
Kevin M. Costantino, Esq. |
cc: Scott D. Hoffman, Esq. (Lazard Ltd)