VIA EDGAR
| July 6, 2007 | ATTORNEYS AT LAW
ONE DETROIT CENTER 500 WOODWARD AVENUE, SUITE 2700 DETROIT, MI 48226-3489 313.234.7100 TEL 313.234.2800 FAX WWW.FOLEY.COM
WRITER’S DIRECT LINE 313.234.7102 THARTMAN@FOLEY.COM EMAIL
CLIENT/MATTER NUMBER 071569-0104 |
Securities and Exchange Commission
100 F. Street, N.E.
Washington, DC 20549
| Attention: | Ms. Michele M. Anderson |
| Mr. John Zitko |
| Re: | Oakmont Acquisition Corp. |
| Amendment No. 5 to Preliminary Proxy Statement on Schedule 14A |
| File No. 0-51423 |
Ladies and Gentlemen:
This letter responds to certain requests for supplemental information made by Ms. Anderson and Mr. Zitko during our telephone calls on July 5, 2007. This response is sent on behalf of our client, Oakmont Acquisition Corp. (the “Company”).
| 1. | The Company has been informed by Morgan Joseph that it has not used any written materials, except for the preliminary proxy statement and the amendments thereto filed by the Company with the SEC and the slide show presentations filed by the Company via Form 8-K on March 18, 2007 and May 4, 2007, during its efforts to assist the Company in raising potential investor awareness in Brooke Credit and the investment potential of the post-merger combined company, and to increase “buy-side” interest in Oakmont common stock, all as described under the caption“Item 1: The Merger Proposal - Oakmont Common Stock Purchases” in Amendment No. 5 to the Preliminary Proxy Statement. |
| 2. | Morgan Joseph has confirmed to the Company that they have not solicited any third parties to directly purchase Oakmont common stock from QVT Financial GP LLC, Dr. Andrew M. Weiss, PhD, or any of the respective affiliates (together with their respective affiliates, “QVT” and “Weiss,” respectively). |
| 3. | Finally, Morgan Joseph has confirmed to the Company that, other than contacts made in the ordinary course of business consistent with customary practice and activities with other similarly situated brokerage clients, Morgan Joseph has not contacted QVT or Weiss to inquire if they wish to sell any shares of Oakmont common stock they may hold. |
BOSTON BRUSSELS CHICAGO DETROIT JACKSONVILLE | LOS ANGELES MADISON MILWAUKEE NEW YORK ORLANDO | SACRAMENTO SAN DIEGO SAN DIEGO/DEL MAR SAN FRANCISCO SILICON VALLEY | TALLAHASSEE TAMPA TOKYO WASHINGTON, D.C. |
Securities and Exchange Commission
July 6, 2007
Page 2
Please call with any questions you may have with respect to the foregoing, or if I may otherwise be of assistance in this matter.
Very truly yours,
Thomas E. Hartman
TEH:sdb
| cc: | Michael C. Azar |