CSQ HOLDING COMPANY 3303 MONTE VILLA PARKWAY BOTHELL, WASHINGTON 98021 PHONE: 425.402.2000 FAX: 425.402.2020 July 27, 2005 VIA FACSIMILE AND EDGAR Mr. Russell Mancuso Branch Chief Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Mail Stop 6010 Washington, D.C. 20549 RE: CSQ HOLDING COMPANY - ACCELERATION REQUEST FOR REGISTRATION STATEMENT ON FORM S-4, COMMISSION FILE NO. 333-124514 Dear Mr. Mancuso: Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, CSQ Holding Company (the "Company") hereby requests that the effective date of the above-referenced Registration Statement on Form S-4 (the "Registration Statement") be accelerated so that the Registration Statement may become effective at 4:30 p.m., Eastern time, on July 29, 2005 or at such later time as the Company may request by telephone to the Commission. The Company hereby authorizes Eric DeJong or Paul Sassalos of Perkins Coie LLP and Michael Hedge of Stradling Yocca Carlson & Rauth, to make such request on our behalf. In connection with the foregoing request, the Company hereby acknowledges that: o should the Securities and Exchange Commission (the "Commission") or the staff, acting pursuant to delegated authority, declare the Registration Statement 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 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 Mr. Russell Mancuso U.S. Securities and Exchange Commission July 27, 2005 Page 2 o 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. Very truly yours, /s/ Michael K. Matysik Michael K. Matysik Chief Financial Officer CSQ Holding Company cc: Perkins Coie LLP Stradling Yocca Carlson & Rauth