December 6, 2013
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Attention: Mr. Tom Kluck
Re: | CatchMark Timber Trust, Inc. |
Registration Statement on Form S-11
File No. 333-191322
Dear Mr. Kluck:
The undersigned as the representatives of the several underwriters of the offering of securities of CatchMark Timber Trust, Inc. (the “Company”) pursuant to the above-referenced Registration Statement on Form S-11, as amended (the “Registration Statement”), Raymond James & Associates, Inc., Robert W. Baird & Co. Incorporated and Stifel, Nicolaus & Company, Incorporated wish to advise you that in connection with the Registration Statement, 52 Preliminary Prospectuses dated November 22, 2013 and 3,675 Preliminary Prospectuses dated November 25, 2013 were distributed during the period beginning on November 22, 2013 and through the date hereof to the five underwriters and others.
We further advise you that we have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby joins in the request of the Company for acceleration of the effective date of the Registration Statement to 4:00 p.m., Washington, D.C. time, on Tuesday, December 10, 2013, or as soon thereafter as practicable.
Securities and Exchange Commission
Page 2
Sincerely, | ||
Raymond James & Associates, Inc., as representative of the several underwriters | ||
By: | /s/ Mark McHugh | |
Name: Mark McHugh | ||
Title: Managing Director | ||
Robert W. Baird & Co. Incorporated, as representative of the several underwriters | ||
By: | /s/ Ryan Engelhardt | |
Name: Ryan Engelhardt | ||
Title: Vice President | ||
Stifel, Nicolaus & Company, Incorporated, as representative of the several underwriters | ||
By: | /s/ Chad M. Gorsuch | |
Name: Chad M. Gorsuch | ||
Title: Managing Director |
cc: | Keith M. Townsend -King & Spalding LLP |