CKX, Inc.
650 Madison Avenue
New York, New York 10022
(212) 838-3100
BY FAX (202) 772-9202
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June 21, 2005
Max A. Webb, Esq.
Daniel H. Morris, Esq.
Office of Chief Counsel
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
RE: CKX, Inc.
Registration Statement on Form S-1 (File No. 333-123995)
Acceleration Request
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, CKX,
Inc. (the "Company") hereby requests the Securities and Exchange Commission (the
"Commission") to accelerate the effective date of the above-referenced
Registration Statement and declare the Registration Statement, as then amended,
effective as of 3:00 P.M., Washington, D.C. time, on Tuesday, June 21, 2005 or
as soon thereafter as practicable.
The Company hereby acknowledges that:
o 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;
o the action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the Company
from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and
o the Company may not assert this action as defense in any proceeding
initiated by the Commission or any person under the federal securities laws
of the United States.
The Company also requests the Commission to specifically confirm such
effective date and time to the Company in writing. In addition, it would be
appreciated if the Commission would advise our counsel, Alan I. Annex, Esq.
(212-801-9323) or Michael L. Pflaum (212-801-6843), by telephone upon the
Registration Statement becoming effective.
Sincerely,
CKX, Inc.
/s/ Jason K. Horowitz
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Name: Jason K. Horowitz
Title: Senior Vice President