CCE Spinco, Inc.
9348 Civic Center Drive
Beverly Hills, California 90210
December
8, 2005
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Re: |
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CCE Spinco, Inc.
Registration Statement on Form 10
File No. 01-32601 |
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Securities and Exchange Commission
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VIA EDGAR |
100 F Street, N.E. |
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Washington, D.C. 20549 |
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Ladies and Gentlemen:
Pursuant to Section 12(d) of the Securities Exchange Act of 1934, as amended (the Exchange
Act) and Rule 12d1-1 promulgated under the Exchange Act, the undersigned hereby requests that the
effectiveness of its Registration Statement on Form 10 (File No. 01-32601) be accelerated so that
such Registration Statement will become effective at 4:00 p.m., EST,
on December 9, 2005, or as
soon thereafter as practicable.
The undersigned acknowledges that:
(a) should the Securities and Exchange Commission (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;
(b) the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the undersigned from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and
(c) the undersigned may not assert staff comments and this action as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of the
United States.
Please contact Daryl Lansdale at (210) 270-9367 or Yvan-Claude Pierre at (212) 318-3084, each
of Fulbright & Jaworski L.L.P., upon effectiveness of the Registration Statement or if you have any
questions regarding this request.
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Very truly yours,
CCE Spinco, Inc.
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By: |
/s/ Randall T. Mays |
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Randall T. Mays |
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Chairman of the Board of Directors |
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