405 LEXINGTON AVENUE
                            NEW YORK, NEW YORK 10174

                                  July 26, 2005

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

                  REGISTRATION STATEMENT ON FORM S-1 (FILE NO. 333-124712)

Ladies and Gentlemen:

         In connection with the above-captioned registration statement, and
pursuant to Rule 461 under the Securities Act of 1933, as amended (the "Act"),
the undersigned, as representative of the underwriters, hereby joins in the
request of the Company that the effective date of such registration statement be
accelerated to 4:30 p.m. (NYT) on Thursday, July 28, 2005, or as soon thereafter
as practicable.

         In accordance with Rule 460 under the Act and in connection with the
foregoing, please note that the undersigned have effected from July 12, 2005
through the date hereof approximately the following distribution of:

         Preliminary Prospectus dated July 12, 2005

         6,200 copies to prospective institutional investors, dealers and others

         Preliminary Prospectus dated July 25, 2005

         3,200 copies to prospective institutional investors, dealers and others

         The undersigned confirms that it has complied with and will continue to
comply with, and it has been informed or will be informed by participating
dealers that they have complied with or will comply with, Rule 15c2-8 under the
Securities Exchange Act of 1934, as amended, in connection with the
above-referenced issue.

                                      Very  truly yours,

                                      MAXIM GROUP LLC, as representative
                                               of the underwriters

                                      By: /s/ Cliff Teller