SEC Division of Corporation Finance no-action letter: Swedish Match AB

555 Eleventh Street,N W.. Suite 1000
Washington, D.C. 20004-1304
Tei: (202) 637-2200 Fax:(202) 637-2207 ww.IW.com FIRM1 AFFILIATE OFFICES BNE~~Is New Yoik Chicago Northern Vimini8 Frankiuii Orange County Hamburg Pans Hony Koog San Digo London San Francisco June 15,2006 Las Angeler Milan Shanghai Silicon Vaiiey MOSCOW Singapore Munich Tokyo New Jersey Washington. D.C. Mauri L. Osheroff, Esq. Associate Director Office of Regulatory Policy Division of Corporation Finance Brian V. Breheny, Esq. Chief Office of Mergers and Acquisitions Division of Corporation Finance David Lynn, Esq. Chief Counsel Office of Chief Counsel Division of Corporation Finance Jonathan Ingram, Esq. Deputy Chief Counsel Office of Chief Counsel Division of Corporation Finance Pamela Carmody, Esq. Special Counsel Office of Mergers and Acquisitions Division of Corporation Finance Securities and Exchange Commission 100 F Street, Station Place, N.E. Washington, D.C. 20549 Re: Proposed Odd-Lot Program of Swedish Match AB, File Number 000-28038 Securities Exchange Act of 1934, Rule 13e-4 Securities Act of 1933. Section 5 Ladies and Gentlemen:
We are writing on behalf of our client, Swedish Match AB (puhl) ("Swedish Match"), to request that the Securities and Exchange Commission (the "Commission") grant exemptive relief to Swedish Match from Rule 13e-4 ("Rule 13e-4") under the Securities Exchange Act of 1934, as amended (the "Exchange Act"), and that the staff of the Division of Corporation Finance (the "Staff') confirm that it will not recommend that the Commission take any enforcement action if the proposed odd-lot program of Swedish Match described in this letter