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Re:
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Acies
Corporation
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Preliminary
Information Statement on Schedule 14C
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Filed
September 3, 2009
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File
No. 000-49724
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1.
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Please
refer to Release No. 34-15230 and discuss the possible anti-takeover
effects of the effective increase in your authorized shares. Please also
discuss other anti-takeover mechanisms that may be present in your
governing documents or otherwise and whether there are any plans or
proposals to adopt other provisions or enter into other arrangements that
may have material anti-takeover consequences. Inform holders that
management might use the additional shares to resist or frustrate a
third-party transaction, favored by a majority of the independent
stockholders, which would provide an above-market
premium.
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2.
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Please
disclose whether you presently have any plans to make grants under the
plan or whether such grants are determinable. If you have a present intent
to make any specific grants, revise your disclosure to provide the
information required by Items 10(a)(2) and 10(b)(2) of Schedule 14A,
applicable through Item 1 of Schedule 14C. If you do not have a
present intent to make any specific grants, please provide a
representation to that
effect.
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Very
truly yours,
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/s/
John S. Gillies
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John
S. Gillies
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Associate
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the
Company is responsible for the adequacy and accuracy of the disclosure in
the filing;
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staff
comments or changes to disclosure in response to staff comments do not
foreclose
the Commission from taking any action with respect to the filing;
and
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the
Company may not assert staff comments as a defense in any proceeding
initiated by
the Commission or any person under the federal securities laws of the
United States
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