0000899140-11-000344.txt : 20110829 0000899140-11-000344.hdr.sgml : 20110829 20110620153517 ACCESSION NUMBER: 0000899140-11-000344 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20110620 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BERKLEY W R CORP CENTRAL INDEX KEY: 0000011544 STANDARD INDUSTRIAL CLASSIFICATION: FIRE, MARINE & CASUALTY INSURANCE [6331] IRS NUMBER: 221867895 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 475 STEAMBOAT ROAD STREET 2: . CITY: GREENWICH STATE: CT ZIP: 06830 BUSINESS PHONE: 2036293000 MAIL ADDRESS: STREET 1: 475 STEAMBOAT ROAD STREET 2: . CITY: GREENWICH STATE: CT ZIP: 06830 CORRESP 1 filename1.htm w6719979.htm


VIA EDGAR

June 20, 2011

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549
Attn:
Jim B. Rosenberg, Senior Assistant Chief Accountant
 
Division of Corporation Finance

Re:
W. R. Berkley Corporation
Form 10-K for the Year Ended December 31, 2010
File No. 1-15202
 
Dear Mr. Rosenberg:

I refer to your letter to me dated May 20, 2011, containing comments of the staff (the “Staff”) of the Securities and Exchange Commission (“SEC”) relating to the above-referenced filing of W. R. Berkley Corporation (“Berkley”), and our responses thereto, sent on our behalf concurrently with this letter.   In connection with such responses to the Staff’s comments, on behalf of Berkley, I acknowledge that:
 
·  
Berkley is responsible for the adequacy and accuracy of the disclosure in its filings with the SEC;
 
·  
Staff comments or changes to disclosure in response to Staff comments do not foreclose the SEC from taking any action with respect to the filings; and
 
·  
Berkley may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.
 
Very truly yours,

/s/ Eugene G. Ballard

Eugene G. Ballard
Senior Vice President -- Chief Financial Officer

cc:
Mark Brunhofer (SEC)
 
Ibolya Ignat (SEC)
 
Ira S. Lederman (Berkley)
 
Jeffrey S. Hochman (Willkie Farr)