ECA Marcellus Trust I
919 Congress Avenue
Suite 500
Austin, TX 78701
June 28, 2010
By Facsimile and EDGAR
Anne Nguyen Parker
Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
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Re: | | ECA Marcellus Trust I Registration Statement on Form S-1 (as amended) File No. 333-165833 (the “Registration Statement”) |
Dear Ms. Parker:
Pursuant to Rule 461 of Regulation C under the Securities Act of 1933, as amended, the ECA Marcellus Trust and Energy Corporation of America (the “Registrants”) hereby request that the effective date of the Registration Statement be accelerated to, and that such Registration Statement be declared effective on, 5:00 p.m. (Washington, D.C. time) on June 30, 2010, or as soon thereafter as practicable unless the Registrants or their outside counsel, Vinson & Elkins L.L.P., request by telephone that this Registration Statement be declared effective at some other time. As requested by the Staff of the Securities and Exchange Commission (the “Commission”) in its letter dated June 3, 2010, the Registrants hereby acknowledge 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 Registrants from their full responsibility for the accuracy and adequacy of the disclosure in the Registration Statement; and |
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| • | | the Registrants may not assert staff comments and the declaration of effectiveness as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
This request has also been transmitted via EDGAR.
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| | | | | | Very truly yours, | | |
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Energy Corporation of America | | | | ECA Marcellus Trust I | | |
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By: | | /s/ Michael S. Fletcher Name: Michael S. Fletcher | | | | By: | | The Bank of New York Mellon Trust Company, N.A. | | |
| | Title: Chief Financial Officer | | | | | | | | |
| | | | | | By: | | /s/ Michael J. Ulrich Name: Michael J. Ulrich | | |
| | | | | | | | Title: Trustee | | |