[LOGO OF TIM HORTONS]
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OPERATED BY THE TDL GROUP Corp.
874 SINCLAIR ROAD, OAKVILLE, ONTARIO L6K 2Y1
TELEPHONE (905) 845-6511 * FACSIMILE (905) 845-0265
March 21, 2006
Via Facsimile (202) 772-9256
Max A. Webb
Securities and Exchange Commission
100 F Street, NE
Mail Stop 3561
Washington, D.C. 20549
Re: Tim Hortons Inc.
Registration Statement on Form S-1
File No. 333-130035
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Dear Mr. Webb:
Tim Hortons Inc. (the "Company"), pursuant to Rule 461 under the Securities
Act of 1933, hereby requests acceleration of the effectiveness of the
above-captioned Registration Statement to March 23, 2006 at 3:00 p.m. Eastern
Time or as soon thereafter as practicable.
The Company hereby acknowledges that:
1. 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;
2. 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
3. The Company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.
Securities and Exchange Commission
March 21, 2006
Page 2
If you have any questions, or require any additional information, please do
not hesitate to contact me by telephone at (614) 764-3536 or by facsimile at
(614) 764-3256.
Sincerely,
/s/ Kerrii B. Anderson
Kerrii B. Anderson
Vice President
cc: Michele M. Anderson, Legal Branch Chief
Cheryl Grant, Staff Attorney
Linda Cverkel, Accountant Branch Chief
Jeffrey Jaramillo, Staff Accountant