KEEFE, BRUYETTE & WOODS, INC. SPECIALISTS IN BANKING AND FINANCIAL SERVICES 787 SEVENTH AVENUE 4TH FLOOR NEW YORK, N.Y. 10019 TOLL FREE MAIN TELEPHONE 1-800-966-1559 212-887-7777 August 5, 2005 Mr. Jeffrey Riedler Assistant Director Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: James River Group, Inc. Registration Statement on Form S-1 File No. 333-124605 Dear Mr. Riedler: James River Group, Inc. (the "Company") has filed a registration statement on Form S-1 (File No. 333-124605), as amended (the "Registration Statement"), with the Securities and Exchange Commission (the "Commission") under the Securities Act of 1933, as amended (the "Securities Act"). In accordance with Rule 461(a) under the Securities Act, we, as representatives of the several underwriters, hereby join in the Company's request that the Commission declare the Registration Statement, as further amended prior to its effectiveness, effective under the Securities Act at noon, Eastern Time, on August 8, 2004, or as soon thereafter as practicable. We, as representative of the several underwriters, are aware of our obligations under the Securities Act. Very truly yours, Keefe, Bruyette & Woods, Inc. For themselves and as representative of the other underwriters By: Keefe, Bruyette & Woods, Inc. By: /s/ Scott Studwell --------------------------------------------- Name: Scott Studwell Title: Vice President
