April 26, 2011
VIA EDGAR AND FACSIMILE
Mr. H. Roger Schwall
Assistant Director
Division of Corporate Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: SMG Indium Resources Ltd. (the “Company”)
Registration Statement on Form S-1, as amended
(File No. 333-165930) (the “Registration Statement”)
Dear Mr. Schwall:
Pursuant to Rule 461 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Sunrise Securities Corp. and Rodman & Renshaw, LLC, on behalf of themselves and as co-representatives of the underwriters of the offering, hereby joins the request of the Company that the effective date of the above-captioned Registration Statement be accelerated so as to permit it to become effective on Thursday, April 28, 2011, at 5:00 p.m., EST, or as soon thereafter as practicable.
Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act, please be advised that the preliminary prospectus, dated March 10, 2011, in connection with the Registration Statement was distributed approximately as follows:
| | Copies to prospective underwriters: | | 255 | |
| | Copies to prospective dealers: | | 220 | |
| | Copies to institutional investors: | | 450 | |
| | Copies to others: | | 50 | |
| | | | | |
| | Total | | 500 | |
The undersigned advises that the underwriters have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
Any questions should be addressed to Jeffrey P. Schultz, at Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. at (212) 935-3000.
| | Very truly yours, | |
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| | SUNRISE SECURITIES CORP. | |
| | | |
| | | | |
| | By: | /s/ Sooyun Hong | |
| | | Name: Sooyun Hong | |
| | | Title: Vice President | |
| | | | |
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| | RODMAN & RENSHAW, LLC | |
| | | |
| | | | |
| | By: | /s/ John Borer | |
| | | Name: John Borer | |
| | | Title: Senior Managing Director | |
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