0001104659-12-041046.txt : 20120702 0001104659-12-041046.hdr.sgml : 20120702 20120531183717 ACCESSION NUMBER: 0001104659-12-041046 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: HEADWATERS INC CENTRAL INDEX KEY: 0001003344 STANDARD INDUSTRIAL CLASSIFICATION: CONCRETE PRODUCTS, EXCEPT BLOCK & BRICK [3272] IRS NUMBER: 870547337 STATE OF INCORPORATION: DE FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 10653 SOUTH RIVERFRONT PARKWAY STREET 2: SUITE 300 CITY: SOUTH JORDAN STATE: UT ZIP: 84095 BUSINESS PHONE: 8019849400 MAIL ADDRESS: STREET 1: 10653 SOUTH RIVERFRONT PARKWAY STREET 2: SUITE 300 CITY: SOUTH JORDAN STATE: UT ZIP: 84095 FORMER COMPANY: FORMER CONFORMED NAME: COVOL TECHNOLOGIES INC DATE OF NAME CHANGE: 19951113 CORRESP 1 filename1.htm

 

Headwaters Incorporated

10653 South River Front Parkway

Suite 300

South Jordan, UT 84095

 

May 31, 2012

 

 

BY EDGAR SYSTEM

 

United States Securities and Exchange Commission

Washington, D.C. 20549

Attention:

Pamela A. Long, Assistant Director

 

Ms. Jessica Dickerson, Staff Attorney

 

Mr. Craig Slivka, Special Counsel

 

RE:                            Headwaters Incorporated

Form T-3

Filed May 4, 2012

File No. 022-28972

 

Request for acceleration of effectiveness

 

Ladies and Gentlemen:

 

Headwaters Incorporated (the “Company”) hereby requests that the effective date of qualification of the above-captioned Form T-3 (the “Form T-3”), be accelerated to 4:00 P.M., Eastern Time, on Monday, June 4, 2012, or as soon thereafter as may be practicable.

 

The Company acknowledges that:

 

· 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;

 

· 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 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.

 


 

We understand that the Staff will consider this request as confirmation by the Company of its awareness of its responsibilities under the federal securities laws as they relate to the offering of the securities covered by the Form T-3.

 

 

Very truly yours,

 

 

 

 

HEADWATERS INCORPORATED

 

 

 

 

 

 

 

By:

/s/ D. Kerry Stubbs

 

Title:

Vice President of Financial Reporting

 

 

cc:  Linda C. Williams, Esq., Pillsbury Winthrop Shaw Pittman LLP
Harlan M. Hatfield, General Counsel

 

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