CORRESP 10 filename10.txt PLATINUM UNDERWRITERS HOLDINGS, LTD. THE BELVEDERE BUILDING 69 PITTS BAY ROAD PEMBROKE, BERMUDA HM 08 September 21, 2005 CONFIDENTIAL Securities and Exchange Commission Division of Corporation Finance Mail Stop 6010 100 F Street, N.E. Washington, D.C. 20549 Attention: Song P. Brandon Re: Platinum Underwriters Holdings, Ltd. Platinum Underwriters Finance, Inc. Registration Statement on Form S-4 Registration No. 333-126883 Ladies and Gentlemen: Under the Securities Act of 1933, as amended, Platinum Underwriters Holdings, Ltd. ("Platinum Holdings") and Platinum Underwriters Finance, Inc. ("Platinum Finance") have filed the above-captioned Registration Statement. Platinum Holdings and Platinum Finance each hereby acknowledges that: (1) the action of the Securities and Exchange Commission (the "Commission") or its staff (the "Staff") acting pursuant to delegated authority in declaring the Registration Statement effective does not foreclose the Commission from taking any action with respect to the filing; (2) the action of the Commission or the Staff acting pursuant to delegated authority in declaring the Registration Statement effective does not relieve Platinum Holdings and Platinum Finance from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and (3) should the Commission or the Staff declare the Registration Statement effective, neither Platinum Holdings nor Platinum Finance may assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Very truly yours, Platinum Underwriters Holdings, Ltd. By: /s/ Joseph F. Fisher ___________________________ Name: Joseph F. Fisher Title: Executive Vice President and Chief Financial Officer Platinum Underwriters Finance, Inc. By: /s/ Joseph F. Fisher ___________________________ Name: Executive Vice President Title: and Chief Financial Officer