0000950123-10-023677.txt : 20110421 0000950123-10-023677.hdr.sgml : 20110421 20100311172419 ACCESSION NUMBER: 0000950123-10-023677 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20100311 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TALBOTS INC CENTRAL INDEX KEY: 0000912263 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-WOMEN'S CLOTHING STORES [5621] IRS NUMBER: 411111318 STATE OF INCORPORATION: DE FISCAL YEAR END: 0130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE TALBOTS DRIVE CITY: HINGHAM STATE: MA ZIP: 02043 BUSINESS PHONE: 7817497600 MAIL ADDRESS: STREET 1: ONE TALBOTS DRIVE CITY: HINGHAM STATE: MA ZIP: 02043 CORRESP 1 filename1.htm corresp
 
The Talbots, Inc.
One Talbots Drive
Hingham, Massachusetts 02043
 
March 11, 2010
 
VIA EDGAR AND FACSIMILE
 
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
 
Attention:  Jay Williamson
 
  Re:  The Talbots, Inc.
Registration Statement on Form S-4 (File No. 333-165111)
 
Dear Mr. Williamson:
 
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, The Talbots, Inc. (the “Registrant”) hereby requests acceleration of the effectiveness of its Registration Statement on Form S-4 (File No. 333-165111), as amended (the “Registration Statement”), to March 12, 2010 at 2:00 p.m., Eastern Time, or as soon as practicable thereafter.
 
In connection with the foregoing request for acceleration of effectiveness, the Registrant hereby acknowledges the following:
 
  •  should the Securities and Exchange Commission (the “Commission”) or the Staff of the Division of Corporation Finance of the Commission (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 Registration Statement;
 
  •  the action of the Commission or Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
 
  •  the Registrant 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.
 
Please contact Morton A. Pierce at (212) 259-6640 or Ivan J. Presant at (212) 259-7405, both of Dewey & LeBoeuf LLP, with any questions you may have concerning this request. In addition, please notify Mr. Pierce and Mr. Presant when this request for acceleration has been granted.
 
THE TALBOTS, INC.
 
  By:  /s/ Richard T. O’Connell, Jr.
Name: Richard T. O’Connell, Jr.
Title: Executive Vice President