CORRESP 1 filename1.htm corresp
(CARDTRONICS LOGO)
March 9, 2010
VIA EDGAR AND FACSIMILE
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 3561
Washington, D.C. 20549-3561
Attention: Mr. Crispino
Re:    Cardtronics, Inc. (the “Registrant”)
Request for Acceleration of Effectiveness
Registration Statement on Form S-3 (File No. 333-164395) (the “Registration Statement”)
Ladies and Gentlemen:
Pursuant to Rule 461 of the rules and regulations promulgated under the Securities Act of 1933, the Registrant hereby requests that the effectiveness of the above-captioned Registration Statement be accelerated so that the Registration Statement will become effective Thursday, March 11, 2010, at 2:00 p.m. Eastern Time, or as soon thereafter as practicable.
The Registrant hereby acknowledges that the disclosure in the Registration Statement is the responsibility of the Registrant. The Registrant hereby further acknowledges that:
    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
 
    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
 
    the Registrant may not assert 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.
(GRAPHIC)


 

(CARDTRONICS LOGO)
Please call Gillian Hobson, the Registrant’s outside legal counsel, at 713.758.3747 with any questions regarding this request for acceleration.
Sincerely,
         
CARDTRONICS, INC.
 
   
By:   /s/ J. Chris Brewster      
  Name:   J. Chris Brewster     
  Title:   Chief Financial Officer     
 
cc:     Gillian Hobson
Vinson & Elkins L.L.P.
Via Facsimile