GLOBAL PARTNERS LP
P.O. Box 9161
800 South Street
Waltham, Massachusetts 02454-9161
(781) 894-8800
| April 5, 2007 |
VIA EDGAR & FACSIMILE TO (202) 772-9369
Mr. Jason Wynn
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-7010
Re: Global Partners LP
Global Finance Corp.
Global Operating LLC
Global Companies LLC
Glen Hes Corp.
Glen Montello Group Corp.
Chelsea Sandwich LLC
Acceleration Request for Registration Statement on Form S-3
File Nos. 333-140525, 333-140525-06, 333-140525-05, 333-140525-04,
333-140525-01, 333-140525-03 and 333-140525-02
Dear Mr. Wynn:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, we hereby request acceleration of the effectiveness of the above-referenced Registration Statement on Form S-3 originally filed by Global Partners LP, Global Finance Corp., Global Operating LLC, Global Companies LLC, Glen Hes Corp., Glen Montello Group Corp. and Chelsea Sandwich LLC (the “Registrants”) on February 8, 2007, as amended, to become effective at 1:00 p.m. Eastern Daylight Time, Monday, April 9, 2007 or as soon as reasonably practicable thereafter.
In connection with this acceleration request, the Registrants hereby acknowledge that:
· should 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;
· the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and
· the Registrants may not assert staff comments and the declaration of effectiveness 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, | ||||||
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| GLOBAL PARTNERS LP | |||||
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| By: | GLOBAL GP LLC | ||||
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| its General Partner | ||||
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| By: | /s/ Thomas J. Hollister | |||
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| Thomas J. Hollister | |||
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| Executive Vice President, | |||
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| Chief Operating Officer and | |||
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| Chief Financial Officer | |||
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| GLOBAL OPERATING LLC | |||||
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| By: | GLOBAL PARTNERS LP | ||||
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| By: | GLOBAL GP LLC | |||
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| its General Partner | |||
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| By: | /s/ THOMAS J. HOLLISTER | ||
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| Thomas J. Hollister | ||
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| Executive Vice President, | ||
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| Chief Operating Officer and | ||
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| Chief Financial Officer | ||
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| GLOBAL COMPANIES LLC | |||||
| CHELSEA SANDWICH LLC | |||||
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| By: | GLOBAL OPERATING LLC | ||||
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| By: | GLOBAL PARTNERS LP | |||
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| By: | GLOBAL GP LLC | ||
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| its General Partner | ||
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| By: | /s/ thomas j. hollister | |
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| Thomas J. Hollister | |
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| Executive Vice President, | |
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| Chief Operating Officer and | |
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| Chief Financial Officer | |
GLP FINANCE CORP. | ||
| GLOBAL MONTELLO GROUP CORP. | |
| GLEN HES CORP. | |
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| By: | /s/ THOMAS J. HOLLISTER |
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| Thomas J. Hollister |
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| Executive Vice President, |
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| Chief Operating Officer and |
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| Chief Financial Officer |
