0001144204-11-023176.txt : 20110606 0001144204-11-023176.hdr.sgml : 20110606 20110420131318 ACCESSION NUMBER: 0001144204-11-023176 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20110420 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Cullen Agricultural Holding Corp CENTRAL INDEX KEY: 0001471256 STANDARD INDUSTRIAL CLASSIFICATION: DAIRY PRODUCTS [2020] IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 22 BARNETT SHOALS ROAD CITY: WATKINSVILLE STATE: GA ZIP: 30677 BUSINESS PHONE: 212-521-4398 MAIL ADDRESS: STREET 1: 22 BARNETT SHOALS ROAD CITY: WATKINSVILLE STATE: GA ZIP: 30677 CORRESP 1 filename1.htm Unassociated Document
 
CULLEN AGRICULTURAL HOLDING CORP.
1431 N Jones Plantation Road
Millen, Georgia 30442


April 20, 2011

VIA EDGAR AND TELECOPY (202) 772-9206

Mr. H. Roger Schwall
Assistant Director
United States Securities and
   Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

 
RE:
Cullen Agricultural Holding Corp. (the "Company")
Registration Statement on Form S-1 originally filed October 27, 2010
(File No. 333-170165) ( the "Registration Statement")                                                                                                

Dear Mr. Schwall:

The Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the Registration Statement so that such Registration Statement will become effective as of 10:00 A.M., Friday, April 22, 2011, or as soon thereafter as practicable.

In connection with the Company’s request for acceleration of effectiveness of the above-referenced Registration Statement, the Company acknowledges the following:

(1)           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;

(2)           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

(3)           The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.
 
Very truly yours,
  
     
 
CULLEN AGRICULTURAL HOLDING CORP.
  
     
       
 
By:
/s/ Eric Watson  
   
Eric Watson, Chief Executive Officer