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SEC Comment Letter for WIRELESS FRONTIER INTERNET INC (CIK 0000038981) — Oct 12, 2004

WIRELESS FRONTIER INTERNET INC (CIK 0000038981)
Date: Oct. 12, 2004 · CIK: 0000038981 · Accession: 0000000000-04-032575

AI Filing Summary & Sentiment

File numbers found in text: 000-08281

Date
October 12, 2004
Author
Melissa Walsh
Form
UPLOAD
Company
WIRELESS FRONTIER INTERNET INC (CIK 0000038981)

Letter

Mail Stop 0406 October 12, 2004 Alex J. Gonzalez Chief Executive Officer Wireless Frontier Internet, Inc. 104 West Callaghan Street Fort Stockton, Texas 79735

Re: Wireless Frontier Internet, Inc. Form 8-K filed October 6, 2004 File No. 000-08281

Dear Mr. Gonzalez:

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. After reviewing this information, we may or may not raise additional comments.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Form 8-K, filed October 6, 2004 1. The disclosure in the first paragraph indicates that your former accountant resigned on September 30, 2004. Accordingly, revise the disclosure regarding disagreements and reportable events to specifically refer to the two most recent fiscal years and subsequent interim period through September 30, 2004. Refer to Item 304(a)(1)(iv) of Regulation S-B. 2. Revise your disclosure with respect to the engagement of a new accountant to indicate whether the new accountant was consulted during the two most recent fiscal years or subsequent interim period through the date of engagement. Provide disclosures to comply with Item 304(a)(2) of Regulation S-B. 3. Within ten business days after the filing of the Form 8-K report, or by October 20, 2004, please file a letter from your former accountant, indicating whether or not they agree with your disclosures in this Form 8-K and any revised statements made in your Form 8-K to the extent that you make changes to comply with our comments. Refer to Item 304(a)(3) of Regulation S-B.

General

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the disclosure in the filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and * 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.

In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comment on your filing.

Please provide the supplemental information requested above within 10 business days from the date of this letter. The supplemental information should be filed as correspondence on EDGAR. The amendment requested should be filed as promptly as possible. Please note that if you require longer than 10 business days to respond, you should contact the staff immediately to request additional time. Any questions regarding the above should be directed to me at (202) 942- 1822, or in my absence, to Robert Benton at (202) 942-1811.

Sincerely,
Melissa Walsh
Staff Accountant

Show Raw Text
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Mail Stop 0406

October 12, 2004

Alex J. Gonzalez
Chief Executive Officer
Wireless Frontier Internet, Inc.
104 West Callaghan Street
Fort Stockton, Texas 79735

Re:   	Wireless Frontier Internet, Inc.
Form 8-K filed October 6, 2004
File No. 000-08281

Dear Mr. Gonzalez:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation
as to why our comments are inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  After
reviewing this information, we may or may not raise additional
comments.

Please understand that the purpose of our review process is to assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing.  We look
forward to working with you in these respects.  We welcome any
questions you may have about our comments or on any other aspect of
our review.  Feel free to call us at the telephone numbers listed at
the end of this letter.

Form 8-K, filed October 6, 2004
1. The disclosure in the first paragraph indicates that your former
accountant resigned on September 30, 2004.  Accordingly, revise the
disclosure regarding disagreements and reportable events to
specifically refer to the two most recent fiscal years and subsequent
interim period through September 30, 2004.  Refer to Item
304(a)(1)(iv) of Regulation S-B.
2. Revise your disclosure with respect to the engagement of a new
accountant to indicate whether the new accountant was consulted
during the two most recent fiscal years or subsequent interim period
through the date of engagement.  Provide disclosures to comply with
Item 304(a)(2) of Regulation S-B.
3. Within ten business days after the filing of the Form 8-K report,
or by October 20, 2004, please file a letter from your former
accountant, indicating whether or not they agree with your
disclosures in this Form 8-K and any revised statements made in your
Form 8-K to the extent that you make changes to comply with our
comments.  Refer to Item 304(a)(3) of Regulation S-B.

General

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  Since the
company and its management are in possession of all facts relating to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In connection with responding to our comment, please provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* 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.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to
our comment on your filing.

Please provide the supplemental information requested above within 10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The
amendment requested should be filed as promptly as possible.  Please
note that if you require longer than 10 business days to respond, you
should contact the staff immediately to request additional time.  Any
questions regarding the above should be directed to me at (202) 942-
1822, or in my absence, to Robert Benton at (202) 942-1811.

Sincerely,

Melissa Walsh
Staff Accountant

Wireless Frontier Internet, Inc.
October 12, 2004
Page 2

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</DOCUMENT>