BALLARD SPAHR ANDREWS & INGERSOLL, LLP
JUSTIN P. KLEIN
Direct Dial: (215) 864-8606
Personal Fax: (215) 864-9166
E-Mail: Kleinj@ballardspahr.com
February 11, 2008
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549 Attention: Jim B. Rosenberg Senior Assistant Chief Accountant |
| | Re: | Harleysville Group Inc. |
| | Form 10-K for the Fiscal Year Ended December 31, 2006 |
| | Filed March 9, 2007 |
| | File No. 000-14697 |
Ladies and Gentlemen:
We are pleased to provide this additional response letter on behalf of Harleysville Group Inc. (“Registrant” or the “Company”) to the Staff’s comments, as conveyed in a voicemail message from Sasha Parikh to the undersigned regarding the Registrant’s Form 10-K filed on March 9, 2007 (the “2006 10-K”). In accordance with that message, the Registrant agrees to provide certain information in future Form 10-K filings that responds to each of the Staff’s comments to the 2006 10-K. Such information will be substantially in the same form as each of the Registrant’s responses to the Staff’s comments to the 2006 10-K.
In addition, the Registrant hereby acknowledges that:
| · | the Registrant is responsible for the adequacy and accuracy of the disclosure in our 2006 10-K; |
| · | comments from the Staff of the U.S. Securities and Exchange Commission (the “Commission”) or changes to disclosure in response to Staff comments in the 2006 10-K do not foreclose the Commission from taking any action with respect to the 2006 10-K; and |
| · | the Registrant may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please direct any questions or comments to me at (215) 864-8606.
Sincerely,
/s/ JUSTIN P. KLEIN
Justin P. Klein
cc: Sasha S. Parikh, Division of Corporation Finance
Arthur E. Chandler, Senior Vice President and Chief Financial Officer
| | Robert A. Kauffman, Esquire, Senior Vice President, Secretary, General Counsel and |
