July 1, 2013
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
| Re: | Otelco Inc. | |
| Request for Withdrawal of Registration Statement on Form S-3 (File No. 333-169738) |
Ladies and Gentlemen:
Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Otelco Inc., a Delaware corporation (the “Company”), and each of the entities listed onExhibit A hereto (together with the Company, the “Registrants”) hereby respectfully request that the Securities and Exchange Commission (the “Commission”) consent to the withdrawal, effective as of the date hereof or as soon as practicable thereafter, of the Registrants’ registration statement on Form S-3 (File No. 333-169738), together with all exhibits thereto (the “Registration Statement”). The Registration Statement was filed by the Registrants on October 4, 2010 to register the sale of up to $56,000,000 of the Company’s Income Deposit Securities. The Registration Statement was declared effective on October 15, 2010.
The Registrants are requesting the withdrawal of the Registration Statement because the Company no longer intends to offer or sell any of its Income Deposit Securities; as a result of the Company’s previously reported restructuring, none of its Income Deposit Securities are currently outstanding. No securities registered under the Registration Statement have been issued or sold.
In accordance with Rule 457(p) under the Securities Act, the Registrants request that all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use.
If you have any questions or require further information regarding this request for withdrawal, please do not hesitate to contact the Registrants’ legal counsel, Steven Khadavi, Esq. of Dorsey & Whitney LLP at (212) 415-9376.
Very truly yours,
OTELCO INC.
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. |
| Title: | Chief Financial Officer |
BLOUNTSVILLE TELEPHONE LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
BRINDLEE MOUNTAIN TELEPHONE LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. |
| Title: | Chief Financial Officer |
COMMUNICATIONS DESIGN ACQUISITION LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
CRC COMMUNICATIONS LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
GRANBY TELEPHONE LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
HOPPER TELECOMMUNICATIONS LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
I-LAND INTERNET SERVICES LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
MID-MAINE TELPLUS LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
MID-MISSOURI HOLDING CORP.
| By: | OTELCO INC., | ||
| Its Successor |
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
| 2 |
OTELCO TELECOMMUNICATIONS LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
OTELCO TELEPHONE LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
SACO RIVER TELEPHONE LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
PINE TREE TELEPHONE LLC
| By: | /s/ Curtis L. Garner, Jr. | ||
| Name: | Curtis L. Garner, Jr. | ||
| Title: | Chief Financial Officer |
cc: Steven Khadavi, Esq.
| 3 |
Exhibit A
| Entity | State of Incorporation or Organization |
| Blountsville Telephone LLC | Alabama |
| Brindlee Mountain Telephone LLC | Alabama |
| Communications Design Acquisition LLC | Delaware |
| CRC Communications LLC | Delaware |
| Granby Telephone LLC | Massachusetts |
| Hopper Telecommunications LLC | Alabama |
| I-Land Internet Services LLC | Missouri |
| Mid-Maine Telplus LLC | Maine |
| Mid-Missouri Holding Corp. | Delaware |
| Otelco Telecommunications LLC | Delaware |
| Otelco Telephone LLC | Delaware |
| Saco River Telephone LLC | Delaware |
| Pine Tree Telephone LLC | Maine |