Securities Exchange Act of 1934
Rule 13d-1(b)(1)(ii)

No Action, Interpretive and/or Exemptive Letter:
Orbis Group

Response of the Office of Mergers and Acquisitions
Division of Corporation Finance

July 16, 2008

Guy P. Lander, Esq.
Carter Ledyard & Milburn LLP
2 Wall Street
New York, NY 10005-2072

Dear Mr. Lander:

We are responding to your letter dated June 27, 2008 addressed to Michael Pressman, as supplemented by telephone conversations with the staff of the Division of Corporation Finance, with regard to your request for no-action relief. Our response is attached to the enclosed photocopy of your letter to avoid having to recite or summarize the facts set forth in your letter. Each defined term in this letter has the same meaning as set forth in your June 27, 2008 letter, unless we indicate otherwise.

The Division of Corporation Finance will not recommend enforcement action to the Commission if Orbis Group and the Qualifying Entities report beneficial ownership on Schedule 13G under those circumstances in which they could so report if they were entities of the type identified in Rule 13d-1(b)(1)(ii) under the Securities Exchange Act of 1934.

This position is based solely upon the facts described and the representations made in your letter. In particular, we note your representations regarding the comparability of the relevant foreign laws that govern Orbis Group and the Qualifying Entities to the U.S. laws governing entities of the type listed in Rule 13d-1(b)(1)(ii). We also note your undertaking to furnish upon request the information that would be required by Schedule 13D.

Any change in the facts described and representations made in your letter may change our conclusion. This letter only expresses our position with respect to recommending enforcement action. The Division of Corporation Finance expresses no view with respect to any other questions that the proposed filings may raise, including, but not limited to, the adequacy of disclosure in, and the applicability of any other federal or state laws to, the Schedule 13G filings to be made, if any, by Orbis Group or the Qualifying Entities.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2008/orbis071608-13d1.htm