ATEL 14, LLC
600 California Street, Sixth Floor
San Francisco, CA 94108
October 5, 2009
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
RE: ATEL 14, LLC
SEC File No. 333-159578
Dear Sir or Madam:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the
undersigned registrant hereby requests that effectiveness of its registration
statement on Form S-1 be accelerated to October 7, 2009, or as soon thereafter
as practicable.
In that regard, the undersigned registrant hereby acknowledges that:
- 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;
- the action of the Commission or 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
- 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,
ATEL 14, LLC
By: ATEL 14 Associates, LLC, Manager
By: /s/ DEAN L. CASH
-------------------------
Dean L. Cash
Chief Executive Officer
ATEL SECURITIES CORPORATION
600 California Street, Sixth Floor
San Francisco, CA 94108
October 5, 2009
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
RE: ATEL 14, LLC
SEC File No. 333-159578
Dear Sir or Madam:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the
undersigned registrant hereby requests that effectiveness of its registration
statement on Form S-1 be accelerated to October 7, 2009, or as soon thereafter
as practicable.
In this connection, and pursuant to Rule 418(a)(7), we hereby advise you as
follows with respect to the distribution of preliminary prospectuses:
(i) the preliminary prospectuses were dated May 29, 2009, July 15, 2009,
September 8, 2009 and October 5, 2009;
(ii) the preliminary prospectuses were distributed during the period from
approximately May 29, 2009 to the date hereof;
(iii) the preliminary prospectuses were furnished to approximately 50-60
broker-dealers as prospective members of the selling group;
(iv) a total of approximately 50-60 of the preliminary prospectuses were
distributed to such broker-dealers;
(v) except as set forth herein, no other preliminary prospectuses were
distributed to any person; and
(vi) the registered securities will be offered and sold only by means of
the final prospectus.
We undertake in connection with the subject offering to comply in all
respects with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended,
and to take all reasonable steps to assure that participating broker-dealers
Securities and Exchange Commission
October 5, 2009
Page 2
comply therewith, and, further, to take all reasonable steps to assure that no
subscriptions are accepted from any person until at least 48 hours after such
person has received a copy of the final prospectus. The undersigned will not
accept as binding on the purchaser any executed contract for the purchase of the
securities covered by the above-referenced registration statement until at least
48 hours after such purchaser has been furnished a copy of the final prospectus.
Very truly yours,
ATEL Securities Corporation
By: /s/ DEAN L. CASH
-------------------------
Dean L. Cash, Chief Executive Officer