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VENABLE;, - SEC

VENABLE;, 8010 Towers Crescent Drive,Suite joa Vienna,Virginia 22182-2707. Telephone 703-760-1600. Facsimile 703-821-8949. Securities Exchange Act 15(a). October 20, 2005. Ms. Catherine McGuire Chief Counsel and Associate Director Division of Market Regulation Securities and Exchange Commission 100 F Street, Washington, 20549. Re: TEOCO Corporation -Request for No-Action Advice Dear Ms. McGuire: We are counsel to TEOCO Corporation, a Delaware corporation (the "Company" or "TEOCO"). The purpose of this letter is to request, on behalf of TEOCO, that the Staff advise that it will not recommend that the Securities and Exchange Commission (the "Commission").

8010 TowersCrescent Drive,Suite joa Telephone 703-760-1600 www.venable.com VENABLE;, Vienna,Virginia 22182-2707 Facsimile 703-821-8949 Securities Exchange Act §15(a) October 20, 2005 Ms. Catherine McGuire Chief Counsel and Associate Director Division of Market Regulation Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549

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