Pyramid Delaware Merger Subsidiary Inactive
Filed: 4 Aug 14, 12:00am
PYRAMID DELAWARE MERGER SUBSIDIARY, INC.
2008 21STSTREET
P.O. BOX 832
BAKERSFIELD, CA 93302
August 1, 2014
VIA EDGAR
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | H. Roger Schwall |
Division of Corporate Finance
| Re: | Withdrawal of Registration Statement on Form S-4 |
Filed on April 25, 2014
File No. 333-195503
Ladies and Gentlemen:
Pyramid Delaware Merger Subsidiary, Inc., a Delaware corporation (the “Company”), hereby requests, pursuant to Rule 477 of the Securities Act of 1933, as amended (the “Securities Act”), that the Registration Statement on Form S-4, together with all exhibits and amendments thereto (File No. 333-195503), as initially filed with the Securities and Exchange Commission (“Commission”) on April 25, 2014 (“Registration Statement”) be withdrawn effective immediately. The Company is seeking withdrawal of the Registration Statement because it will not be part of the reincorporation process as disclosed in the Registration Statement. The Company’s parent, Pyramid Oil Company, will be proceeding with the merger transaction described in the Registration Statement and subsequently will be filing a separate registration statement on Form S-4. The Registration Statement has not been declared effective and none of the Company’s securities have been sold pursuant to the Registration Statement.
In accordance with Rule 457(p) of the Securities Act, the Company requests that all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use to its parent, Pyramid Oil Company.
Accordingly, we request that the Commission issue an order granting the withdrawal of the Registration Statement (“Order”) effective as of the date hereof or at the earliest practicable date hereafter. Please provide a copy of the Order to Reid A. Godbolt, Esq., of Jones & Keller, P.C., via email at rgodbolt@joneskeller.com or via facsimile at (303) 573-8133.
Should you have any questions regarding this request for withdrawal, please contact Reid A. Godbolt, Esq., of Jones & Keller, P.C., by telephone at (303) 573-1600.
| Very truly yours, | ||
| PYRAMID DELAWARE MERGER SUBSIDIARY, INC. | ||
| By: | /s/ Michael D. Herman | |
| Name: Michael D. Herman | ||
| Title: President and Chief Executive Officer | ||