June 20, 2008
VIA EDGAR
Mr. Daniel F. Duchovny
Special Counsel
Office of Mergers & Acquisitions
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-3628
| Re: | USANA Health Sciences, Inc. |
Schedule 13E-3; File No. 005-55565
Filed June 3, 2008, as amended June 5, 2008
Filed by Unity Acquisition Corp. et al.
Schedule TO; File No. 000-55565
Filed June 2, 2008, as amended June 5, 2008
Filed by Unity Acquisition Corp. et al.
Schedule 13D/A filed by Gull Holdings, Ltd. et al.
Filed June 2, 2008
File No. 005-55565
Dear Mr. Duchovny:
This letter is submitted by Unity Acquisition Corp., Gull-Unity Holding Corp., Gull Holdings, Ltd., Myron W. Wentz, David A. Wentz, Jacquelyn R. Wentz, Bryan Wentz, Annette Wentz, Paul & Jane Meyer Family Foundation, Alice Jane Meyer, Paul J. Meyer, Centre Island Properties, Ltd., Waco Boys Club Foundation, Inc., L-K Marketing Group, LLC and Beagle Irrevocable Asset Trust (collectively, the “Filing Persons”). Please be advised that, in connection with the comments issued by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), received by facsimile on June 16, 2008, with regard to the above-referenced filings, each Filing Person hereby acknowledges that:
| • | The Filing Persons are responsible for the adequacy and accuracy of the disclosure in the filings; |
| • | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and |
| • | The Filing Persons 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. |
Please call Lisa Haddad of Goodwin Procter LLP at (617) 570-8311 if you have any questions.
[ Signature pages follow ]
Very Truly Yours,
| GULL HOLDINGS, LTD. |
| /s/ Toby L. Marshall /s/ Mark J. Lewin |
| Signature |
| Mark J. Lewin and Toby L. Marshall, For and on behalf of Enmyn Limited Corporate Director |
| Name/Title |
| GULL-UNITY HOLDING CORP. |
| /s/ David A. Wentz |
| Signature |
| David A. Wentz, President |
| Name/Title |
| UNITY ACQUISITION CORP. |
| /s/ David A. Wentz |
| Signature |
| David A. Wentz, Vice President |
| Name/Title |
| MYRON W. WENTZ |
| /s/ Myron W. Wentz |
| Signature |
| DAVID A. WENTZ |
| /s/ David A. Wentz |
| Signature |
| JACQUELYN R. WENTZ |
| /s/ Jacquelyn R. Wentz |
| Signature |
| BRYAN WENTZ |
| /s/ Bryan Wentz |
| Signature |
| ANNETTE WENTZ |
| /s/ Annette Wentz |
| Signature |
| PAUL & JANE MEYER FAMILY FOUNDATION |
| /s/ William Terry Irwin |
| Signature |
| William Terry Irwin, Vice President |
| Name/Title |
| PAUL J. MEYER |
| /s/ Paul J. Meyer |
| Signature |
| ALICE JANE MEYER |
| /s/ Alice Jane Meyer |
| Signature |
| CENTRE ISLAND PROPERTIES, LTD. |
| /s/ Christopher Whorms |
| Signature |
| Christopher Whorms, Director |
| Name/Title |
| WACO BOYS CLUB FOUNDATION, INC. |
| /s/ Eugene R. Franklin |
| Signature |
| Eugene R. Franklin, Vice President |
| Name/Title |
| L-K MARKETING GROUP, LLC |
| /s/ Kevin Rhea |
| Signature |
| Kevin Rhea, President |
| Name/Title |
| BEAGLE IRREVOCABLE ASSET TRUST |
| /s/ Eugene R. Franklin |
| Signature |
| Eugene R. Franklin, Trustee |
| Name/Title |