CORRESP 1 filename1.htm corresp
 

[THE ADVISORY BOARD COMPANY LETTERHEAD]
February 8, 2007
VIA EDGAR AND OVERNIGHT COURIER
Linda van Doorn
Senior Assistant Chief Accountant
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
     
Re:
  The Advisory Board Company
 
  Form 10-K for the year ended March 31, 2006
 
  Filed June 14, 2006
 
  File No. 000-33283
Dear Ms. van Doorn:
     On behalf of The Advisory Board Company (the “Company”), this responds to your letter dated January 30, 2007, regarding the Company’s Annual Report on Form 10-K for the year ended March 31, 2006. For ease of reference, your comment is set forth below, followed by our response.
Form 10-K for the Year Ended March 31, 2006
Exhibit 31.1 and 31.2 Certifications
Comment
  1.   Please confirm to us that you will revise your certifications in all future filings to conform the language in paragraphs 4d and 5 to exactly match the corresponding language in Item 601(b)(31)(i) of Regulation S-K.

 


 

Securities and Exchange Commission
February 8, 2007
Page 2
Response
  1.   We acknowledge your comment. The Company will revise the certifications in all future filings to conform the language in paragraphs 4d and 5 to exactly match the corresponding language in Item 601(b)(31)(i) of Regulation S-K.
     The Company hereby acknowledges that:
    the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
 
    comments by the staff of the Securities and Exchange Commission or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and
 
    the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
     If you should have any questions or further comments with respect to the Company’s filings, please direct them to me at (202) 266-5600. Facsimile transmissions may be sent to me at (202) 266-5700.
         
  Very truly yours,

/s/  Michael T. Kirshbaum         
Michael T. Kirshbaum
Chief Financial Officer
 
 
     
     
     
 
cc: Steven R. Finley