corresp
VECTOR GROUP LTD.
100 S.E. Second Street
Miami, Florida 33131
(305) 579-8000
May 5, 2010
VIA FACSIMILE AND EDGAR
U.S. Securities and Exchange Commission
100 F. Street, N.E., Mail Stop 3561
Washington, D.C. 20549
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Attn: |
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Amanda Ravitz, Branch Chief-Legal
Michelle Lacko, Staff Attorney |
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Re: |
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Vector Group Ltd. Request for Acceleration of
Effective Date of Registration Statement on Form S-4
(SEC File No. 333-166197), filed on May 5, 2010 |
Dear Mses. Ravitz and Lacko:
Pursuant to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange
Commission (the Commission) under the Securities Act of 1933, as amended, Vector Group
Ltd. (the Company) hereby requests acceleration of the effective date of the
above-referenced Registration Statement (the filing) so that it will become effective at
3:00 p.m., Washington D.C. time, on May 6, 2010 or as soon thereafter as practicable.
The Company acknowledges that the disclosure in the filing is the responsibility of the
Company. The Company represents to the Commission that 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, and the Company represents that it will 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.
The Company further acknowledges that 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.
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Very truly yours, |
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Vector Group Ltd. |
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By:
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/s/ J. Bryant Kirkland III |
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Name:
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J. Bryant Kirkland III |
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Vice President, Treasurer and CFO |
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