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U.S. Securities and Exchange Commission

Securities Act of 1933 - Rule 144(d)

October 5, 2007

Response of the Office of Chief Counsel
Division of Corporation Finance


Abacus Investments Limited
Incoming letter dated October 1, 2007

Based on the facts presented, the Division's views are as follows. Capitalized terms have the same meanings defined in your letter. For purposes of satisfying the holding period requirements of Rule 144(d) and Rule 144(k) under the Securities Act, the Abacus Beneficial Owners, including the Abacus Beneficial Owners that are affiliates of BMP, may tack the holding period of Abacus to their own with respect to the BMP Common Stock. So long as they are not affiliates of BMP and have not been within the preceding three months, Abacus Beneficial Owners who have a holding period when combined with the holding period of Abacus of two years or more may immediately resell the BMP Common Stock in reliance upon Rule 144(k). Sales of BMP Common Stock under Rule 144(k) by Abacus Beneficial Owners that are not affiliates of BMP would not be aggregated with sales by Abacus Beneficial Owners that are affiliates of BMP, assuming that the affiliated Abacus Beneficial Owners are not acting in concert with any of the non-affiliated Abacus Beneficial Owners. Finally, persons ineligible to sell in reliance on Rule 144(k) will share a single volume limitation under Rule 144(e) in the year following the transfer from Abacus.

These positions are based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach different conclusions.


Heather L. Maples
Special Counsel

Incoming Letter:

The Incoming Letter is in Acrobat format.


Modified: 10/22/2007