-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, Ixi5b7xmfRJ4itMh9PLrfWf+gYFDSIYwdsgzQDWE7McJRHT3cFp2UNILcrSlyM1W kwBYQ9JsqZFzr9A4+pORkw== 0000893220-06-000263.txt : 20061004 0000893220-06-000263.hdr.sgml : 20061004 20060213170124 ACCESSION NUMBER: 0000893220-06-000263 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060213 FILER: COMPANY DATA: COMPANY CONFORMED NAME: IKON OFFICE SOLUTIONS INC CENTRAL INDEX KEY: 0000003370 STANDARD INDUSTRIAL CLASSIFICATION: WHOLESALE-COMPUTER & PERIPHERAL EQUIPMENT & SOFTWARE [5045] IRS NUMBER: 230334400 STATE OF INCORPORATION: OH FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: PO BOX 834 CITY: VALLEY FORGE STATE: PA ZIP: 19482 BUSINESS PHONE: 6102968000 MAIL ADDRESS: STREET 1: PO BOX 834 CITY: VALLEY FORGE STATE: PA ZIP: 19482 FORMER COMPANY: FORMER CONFORMED NAME: ALCO STANDARD CORP DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: ALCO CHEMICAL CORP DATE OF NAME CHANGE: 19680218 CORRESP 1 filename1.txt [LETTERHEAD OF IKON OFFICE SOLUTIONS, INC.] February 13, 2006 Barbara C. Jacobs Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: IKON OFFICE SOLUTIONS, INC. REGISTRATION STATEMENT ON FORM S-4 (FILE NO. 333-130513) Dear Ms. Jacobs: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, registrant IKON Office Solutions, Inc. (the "Company") hereby respectfully requests that the above-referenced Registration Statement on Form S-4 (the "Registration Statement") be declared effective at 2:00 p.m., Eastern Daylight Time, on Wednesday, February 15, 2006, or as soon thereafter as is practicable. In connection with the foregoing request, the Company acknowledges that (i) should the Securities and Exchange Commission (the "Commission") or the staff of the Commission (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; (ii) 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 accuracy and adequacy of the disclosure in the filing; and (iii) 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. As soon as the Securities and Exchange Commission has declared such Registration Statement effective, please call Sarah S. Jones at Cravath, Swaine & Moore LLP at (212) 474-1365, and then send written confirmation to the addresses listed on the cover of the Registration Statement. Sincerely, /s/ Mark A. Hershey, Esq. ------------------------------ Mark A. Hershey, Esq. Senior Vice President, General Counsel and Secretary -----END PRIVACY-ENHANCED MESSAGE-----