Martin H. Dodd
General Counsel
Direct: 860-298-6212
Fax: 860-298-6323
Email: mdodd@trcsolutions.com
January 24, 2011
Mr. Jay Ingram
Legal Branch Chief
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street
Washington, DC 20549
Re: TRC Companies, Inc.
Registration Statement on Form S-3
Filed December 1, 2010 and Amended
As of January 7, 2011
File No. 333-170909
Dear Mr. Ingram:
This morning I spoke by telephone with Erin Jaskot in your office. We received your letter dated December 15, 2010 and responded to the comments therein on January 7, 2011. We understand from Ms. Jaskot that the Commission has cleared those comments, and we may proceed to make the Registration Statement effective.
Accordingly, we hereby request that the Registration Statement be effective as of the earliest practical time on Friday, January 28, 2011. In connection with this request, we acknowledge that:
· should the Commission or 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 the effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Thank you for your kind consideration.
Very truly yours, |
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/s/ Martin H. Dodd |
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Martin H. Dodd |
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MHD/pah |
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cc: Erin Jaskot