0000905148-11-000489.txt : 20110408 0000905148-11-000489.hdr.sgml : 20110408 20110217135020 ACCESSION NUMBER: 0000905148-11-000489 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20110217 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FactorShares 2X: S&P500 Bull/TBond Bear CENTRAL INDEX KEY: 0001482875 STANDARD INDUSTRIAL CLASSIFICATION: [6221] IRS NUMBER: 800561294 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: FACTOR CAPITAL MANAGEMENT, LLC STREET 2: 1 PENN PLAZA, 36TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10119 BUSINESS PHONE: (212) 786-7481 MAIL ADDRESS: STREET 1: FACTOR CAPITAL MANAGEMENT, LLC STREET 2: 1 PENN PLAZA, 36TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10119 FORMER COMPANY: FORMER CONFORMED NAME: FactorShares S&P US Equity Premium DATE OF NAME CHANGE: 20100304 FORMER COMPANY: FORMER CONFORMED NAME: FactorShares S&P 2x US Equity Premium DATE OF NAME CHANGE: 20100201 CORRESP 1 filename1.htm efc11-157_corresp.htm
FACTORSHARES 2X: S&P500 BULL/TBOND BEAR
C/O FACTOR CAPITAL MANAGEMENT, LLC
1 PENN PLAZA, 36th FLOOR
NEW YORK, NEW YORK 10119
 
 
February 17, 2011
 
Kristina Aberg
Attorney Advisor
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street NE
Washington, D.C. 20549
 
 
 
Re:
FactorShares 2X: S&P500 Bull/TBond Bear (the “Company”)
Registration Statement on Form S-1 (File No. 333-164754)

 
Dear Ms. Aberg:
 
We hereby request that the effective date for the above-captioned Registration Statement be accelerated so that it will be declared effective under the Securities Act of 1933, as amended, at 9:00 a.m. on February 22, 2011, or as soon thereafter as reasonably practicable.
 
We hereby acknowledge that:
 
 
1.
should the Securities and Exchange Commission (the “Commission”), or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare this filing effective, it does not foreclose the Commission from taking any action with regard 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 responsibility for the adequacy and accuracy of the disclosure in this filing; and
 
 
3.
the Company 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.
 
Very truly yours,
 
FACTORSHARES 2X: S&P500 BULL/TBOND BEAR
   TIMBER HILL LLC    
By:
 Factor Capital Management, LLC,      
 
 its Managing Owner      
 
        
By:  /s/ Stuart Rosenthal                               By:  /s/ Bradford Jacobowitz                          
  Name:  Stuart Rosenthal   Name:  Bradford Jacobowitz  
  Title:  Chief Executive Officer   Title:  Chief Compliance Officer