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MorningLightMountain

12/07/09 8:15 PM

#266943 RE: loanranger #266927

LR, why do you believe SPNG wasn't subject to 1934 regs before the filing of the 8-A12G this fall????

PS: see this link, doc released on 8/8/2008.....sure looks to ME as if they are claiming rights as a 1934 Co......

http://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001201251&owner=exclude&count=40

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
August 7, 2008
-----------------------------------------
ORDER GRANTING CONFIDENTIAL TREATMENT
UNDER THE SECURITIES EXCHANGE ACT OF 1934

Spongetech Delivery Systems, Inc.
File No. 333-100925 - CF# 21981
-----------------------------------------
Spongetech Delivery Systems, Inc. submitted an application under rule 24b-2 requesting confidential treatment for information it excluded from the Exhibits to a Form 10-QSB filed on April 15, 2008.
Based on representations by Spongetech Delivery Systems, Inc. that this information qualifies as confidential commercial or financial information under the Freedom of Information Act, 5 U.S.C. 552(b)(4), the Division of Corporation Finance has determined not to publicly disclose it. Accordingly, excluded information from the following exhibit(s) will not be released to the public for the time period(s) specified:
Exhibit 10.1 through April 18, 2013
Exhibit 10.3 through April 18, 2013
For the Commission, by the Division of Corporation Finance, pursuant to delegated authority:
L. Jacob Fien-Helfman
Special Counsel and Information Officer

TEX

12/07/09 8:52 PM

#266952 RE: loanranger #266927

This again...

Are you saying you think a company "graduates" from being a '33 company to being a '34 company?