0001171843-14-000826.txt : 20140324 0001171843-14-000826.hdr.sgml : 20140324 20140219180109 ACCESSION NUMBER: 0001171843-14-000826 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140219 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Embarr Downs, Inc. CENTRAL INDEX KEY: 0001552719 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-RACING, INCLUDING TRACK OPERATION [7948] IRS NUMBER: 463403755 FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 205 AVE DEL MAR #974 CITY: SAN CLEMENTE STATE: CA ZIP: 92674 BUSINESS PHONE: 949-461-1471 MAIL ADDRESS: STREET 1: 205 AVE DEL MAR #974 CITY: SAN CLEMENTE STATE: CA ZIP: 92674 FORMER COMPANY: FORMER CONFORMED NAME: Embar Downs, Inc. DATE OF NAME CHANGE: 20130918 FORMER COMPANY: FORMER CONFORMED NAME: GLOBALGROUP INVESTMENT HOLDINGS INC DATE OF NAME CHANGE: 20120620 CORRESP 1 filename1.htm corresp_021914.htm
VIA EDGAR February 19, 2014
 
Ryan Adams
J. Nolan McWilliams
United States Securities and Exchange Commission
Washington, D.C. 20549
 
 
RE:
Embarr Downs, Inc.
 
Registration Statement on Form S-1
 
Filed February 7, 2014
 
File No. 333-192804

In accordance with Rule 461 under the Securities Act of 1933, Embarr Downs, Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement in order that the Registration Statement shall become effective at 12:00 p.m., Washington, D.C. time, on Monday, February 24, 2014, or as soon thereafter as is practicable.
 
 
The Company hereby acknowledges that:
 
 
•
  
should 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 Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
 
 
•
  
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 laws of the United States.
 
 
 
Sincerely,

Embarr Downs, Inc.
  
       
       
  By: /s/ Joseph Wade  
  Name:
Joseph Wade
  
  Title:
CEO/President