Credit Suisse Securities (USA) LLC
11 Madison Avenue
New York, NY 10010
Goldman, Sachs & Co.
85 Broad Street
New York, NY 10004
| November 4, 2009 |
Re: | STR Holdings (New) LLC |
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mr. Jay Ingram
Dear Mr. Ingram:
Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933 (the “Act”), we, as representatives of the several Underwriters, wish to advise you that the Preliminary Prospectus issued October 22, 2009 was distributed during the period October 22, 2009 through 5:00 p.m., Eastern Standard Time, November 2, 2009, as follows:
Preliminary Prospectus |
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| 5356 to 8 Underwriters and Dealers |
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| 2199 to 2199 Institutions |
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| 9 to 3 Rating Agencies |
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| 0 to 0 Others |
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Total: | 7564 |
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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.
In accordance with Rule 461 of the Act, we hereby join in the request of STR Holdings (New) LLC for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 5:30PM Eastern Standard Time on November 5, 2009, or as soon thereafter as practicable.
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| Very truly yours, | |
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| CREDIT SUISSE SECURITIES (USA) LLC | |
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| GOLDMAN, SACHS & CO. | |
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| Acting severally on behalf of themselves and the several Underwriters | |
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| By: | Credit Suisse Securities (USA) LLC |
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| /s/ Mark Filipski |
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| Name: Mark Filipski |
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| Title: Managing Director |
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| By: | Goldman, Sachs & Co. |
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| /s/ Goldman, Sachs & Co. |
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| Goldman, Sachs & Co. |
