Standard Pacific Corp.
15360 Barranca Parkway
Irvine, CA 92618
August 25, 2015
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attn: | Jay Ingram, Legal Branch Chief |
Kamyar Daneshvar, Staff Attorney
Lisa Etheredge, Staff Accountant
Anne McConnell, Staff Accountant
| Re: | Standard Pacific Corp. |
Registration Statement on Form S-4 (File No. 333-205452)
Request for Acceleration
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Standard Pacific Corp. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form S-4 (File No. 333-205452), as amended (the “Registration Statement”), so that it will be declared effective at 9:00 a.m. Eastern Time on August 27, 2015, or as soon as possible thereafter.
The Company hereby acknowledges that:
| (i) | should the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; |
| (ii) | the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and |
| (iii) | the Company may not assert Staff comments and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please notify Robb Tretter of Ropes & Gray LLP, counsel to the Company, at(212) 596-9512 as soon as the Registration Statement has been declared effective.
| Very truly yours, | ||
| STANDARD PACIFIC CORP. | ||
| By: | /s/ John P. Babel | |
| John P. Babel | ||
Executive Vice President, General Counsel and Secretary | ||
cc: Robb L. Tretter,Ropes & Gray LLP
