| Re: | Burger King Holdings, Inc. (“Holdings”) and Burger King Corporation (“BKC”) Registration Statement on Form S-4 (File No. 333-170614) |
| • | 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 BKC and the Guarantors from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and | ||
| • | BKC and the Guarantors 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. |
| Very truly yours, Burger King Holdings, Inc. |
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| By: | /s/ Anne Chwat | |||
| Name: | Anne Chwat | |||
| Title: | General Counsel | |||
| Burger King Corporation |
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| By: | /s/ Anne Chwat | |||
| Name: | Anne Chwat | |||
| Title: | General Counsel | |||
| BK Acquisition, Inc. BK CDE, Inc. Burger King Interamerica, LLC Burger King Sweden Inc. Distron Transportation Systems, Inc. Moxie’s, Inc. The Melodie Corporation TPC Number Four, Inc. TQW Company |
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| By: | /s/ Anne Chwat | |||
| Name: | Anne Chwat | |||
| Title: | General Counsel | |||