[Letterhead of Hughes Supply, Inc.]
VIA FACSIMILE AND EDGAR
July 19, 2005
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Pamela A. Long, Assistant Director
Re: | Hughes Supply, Inc. Registration Statement on Form S-4/A File No. 333-124792 and 333-124792-01 through 38 Acceleration Request |
Ladies and Gentlemen:
In connection with Hughes Supply, Inc.’s (the “Company”) above-referenced pending Registration Statement on Form S-4/A (the “Filing”) under the Securities Act of 1933, as amended, the Company and the subsidiaries of the Company that are additional registrants with respect to the Filing (the “Additional Registrants”) hereby request acceleration of the effectiveness of the Registration Statement at 4:00 p.m. on July 21, 2005 or as soon thereafter as practicable.
By filing this acceleration request, the Company and each of the Additional Registrants hereby acknowledges the following:
• | 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; |
• | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Filing effective, does not relieve the Company and the Additional Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Filing; and |
• | the Company and the Additional Registrants may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Very truly yours,
HUGHES SUPPLY, INC. | ||
By: | /s/ John Z. Paré | |
John Z. Paré, Esq. Senior Vice President and General Counsel |
SUBSIDIARIES:
COMPASS UTILITY SUPPLY, LTD. HUGHESBUILDING MATERIALS GROUP, INC. HUGHES CANADA, INC. HUGHES GP & MANAGEMENT, INC. HUGHES INSURANCE HOLDINGS, INC., HUGHES MRO GROUP, INC. HUGHES PLUMBING GROUP, INC. HUGHES SUPPLY MANAGEMENT, INC. HUGHESSUPPLY MANAGEMENT SERVICES, INC. HUGHES SUPPLY SHARED SERVICES, INC. HUGHES UTILITIES GROUP, INC. MEREX CORPORATION MONTANA ELECTRIC SUPPLY MONTANA ELECTRIC SUPPLY, INC. SOUTHWEST POWER, INC. WESTERN STATES ELECTRIC, INC. WORLD-WIDE TRAVEL NETWORK, INC. WES ACQUISITION CORPORATION (d/b/a Wyoline Electric Supply, Inc.) |
By: | /s/ David Bearman | |
David Bearman Treasurer | ||
HUGHESBUILDING MATERIALS HOLDINGS, LLC HUGHES ELECTRIC HOLDINGS, LLC HUGHES HOLDINGS, LLC HUGHES MRO HOLDINGS, LLC HUGHES PLUMBING HOLDINGS, LLC HUGHES UTILITIES HOLDINGS, LLC HUGHES WATER & SEWER HOLDINGS, LLC |
UTILITYPRODUCTS SUPPLY COMPANY, LLC | ||
By: | HUGHES GP & MANAGEMENT, INC., manager | |
By: | /s/ David Bearman | |
David Bearman Treasurer | ||
HUGHES BUILDING MATERIALS, LTD. HUGHES ELECTRIC SUPPLY, LTD. HUGHES MRO, LTD. HUGHES PLUMBING SUPPLY, LTD. HUGHES UTILITIES, LTD. HUGHES WATER & SEWER, LTD. SOUTHWEST STAINLESS, LP |
By: | HUGHES GP & MANAGEMENT, INC., general partner | |
By: | /s/ David Bearman | |
David Bearman Treasurer |
PROVALUE, LLC | ||
By: | HUGHES SUPPLY SHARED SERVICES, INC.,manager | |
By: | /s/ David Bearman | |
David Bearman Treasurer | ||
HSI FUNDING, LLC HSI IP, INC. SWS ACQUISITION, LLC |
By: | /s/ John Z. Paré | |
John Z. Paré Assistant Secretary |