Noteworthy Letters Just Released. . .

 Xplornet Communications Inc.
Investment Company Registration
The Canadian company seeks the staff's assurance that it may issue securities in private capital-raising transactions without registering as an investment company under the Investment Company Act. The company provides broadband Internet access in sparsely populated areas across Canada under a Canadian federal government program. The company makes loans to Xplornet Broadband Inc. ("XBI") to enable the company to access XBI's spectrum and terrestrial transmission facilities so that the company can provide Internet access to customers. The company is required under Canadian GAAP to prepare its financial statements on a consolidated basis as if XBI were a wholly or majority owned subsidiary of the company. The company's cash management investments are limited to Canadian government securities and other Canadian highly liquid, short-term, high quality bank issued or money market securities, and are intended to ensure that the company will be able to meet its obligations to fund its operations and finance the acquisition of spectrum licenses and network equipment. The company will not invest or trade in securities for short-term speculative purposes, and its income is predominately derived from its non-investment operations.