December 3, 2010
Via EDGAR and Facsimile Transmission
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
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Re: | | CTPartners Executive Search Inc. (the “Company”) Registration Statement on Form S-1 Filed September 3, 2010 File No. 333-169224 |
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 2:00 PM ET on December 6, 2010, or as soon thereafter as is practicable.
The Company, through its undersigned counsel, hereby acknowledges 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; |
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| • | | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
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| • | | the Company may not assert this action as a defense in any proceeding initiated by the Commission or any under the federal securities laws of the United person States. |
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| Very truly yours,
Ulmer & Berne LLP | |
| By: | /s/ Howard Groedel | |
| | Name: | Howard Groedel | |
| | Title: | Partner | |
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cc: | | Brian M. Sullivan, Chief Executive Officer CTPartners Executive Search Inc. (via facsimile only) |
278/lg/1871967.1