October 5, 2007
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Kate Tillan
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| Re: | | SEC Comments of September 24, 2007 |
Dear Ms. Tillan:
This letter is in response to your comment letter dated September 24, 2007. The company acknowledges that:
| | • | | the company is responsible for the adequacy and accuracy of the disclosure in the filing: |
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| | • | | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
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| | • | | the company 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. |
Sincerely,
/s/ Debra Young
Debra Young
Vice President & Chief Financial Officer
