January 3, 2006
Larry Spirgel
Assistant Director
Mail Stop 0407
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: | MDC Partners Inc. |
| Form 10-K for Fiscal Year Ended December 31, 2004; Filed April 18, 2005 | |
| Form 10-Q for Fiscal Quarter Ended September 30, 2005; | |
| File No. 1-13178 |
Dear Mr. Spirgel:
Set forth below are the additional responses and acknowledgments of MDC Partners Inc. (the “Company”) to the comments of the Staff of the Division of Corporation Finance, which were set forth in your most recent letter dated December 29, 2005 (the “December 29th Letter”) regarding the Company’s above-referenced filings.
As requested by the Staff in the December 29th letter, the Company hereby confirms that it will comply with its obligation to continue to assess the Company’s reporting segment presentation for compliance with FAS 131 and, if a different determination is reached in future reporting periods, the Company will provide disaggregated information that complies with FAS 131. Furthermore, the Company hereby confirms that it will fully comply with the Staff's comments by disclosing required information in the MD&A section of future filings with the Commission.
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Mr. Larry Spirgel
Securities and Exchange Commission
January 3, 2006
Page 2 of 2
Please direct any questions concerning the above responses to the undersigned (telephone: (212) 463-3628; fax: (212) 463-3274), with a copy to Ethan Klingsberg (Cleary Gottlieb Steen & Hamilton LLP; fax: (212) 225-3999).
Very truly yours,
___________________________________
Steven Berns,
President and Chief Financial Officer
MDC Partners Inc.
___________________________________
Mitchell Gendel,
General Counsel & Corporate Secretary
MDC Partners Inc.
Enclosures
cc: | Melissa Hauber |
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| Robert S. Littlepage, Jr. |
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| Securities and Exchange Commission | |||
Miles S. Nadal, Chairman and Chief Executive Officer
| Members of the Audit Committee |
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| MDC Partners Inc. |
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| Bruce Toner |
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| KPMG |
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| Ethan Klingsberg, Esq. |
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| Cleary Gottlieb Steen & Hamilton LLP | ||||||
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