SEC Comment Letter for INTRAC INC (CIK 0000050710) — Jan 7, 2005
INTRAC INC (CIK 0000050710)
Date: Jan. 7, 2005 · CIK: 0000050710 · Accession: 0000000000-05-001349
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<TYPE>LETTER
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<FILENAME>filename1.txt
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December 29, 2004
Via Facsimile at (212) 554-4554 and U.S. Mail
Mr. Fred Mermelstein
President
Intrac, Inc.
130 West 42nd Street
New York, New York 10036
Re: Intrac, Inc
Schedule 14F-1 filed on December 20, 2004
File No. 5-80010
Dear Mr. Mermelstein:
We have the following comments on the above-referenced
filings.
Schedule 14F-1
1. Please supplementally confirm that you are not required to
provide the disclosure required by Item 404 of Regulation S-B.
Officer, Directors and Key Employees following the Merger
2. Please ensure that the biographical information of the
Directors and executive officers of the company complies with
Item 401 of Regulation S-B. For example, you should revise
Mr. Carr`s biography to completely describe his business
experience for the past five years, disclosing the dates of
experience by month and year. Also, ensure that there are no
gaps or ambiguities regarding time in the five-year business
sketches you provide.
Board Committee, page 7
3. Please provide the disclosure required by Item 7(d)(2)
(i) Item 7(f) and Item 7(h) of Schedule 14A.
Closing Information
Please respond to our comments promptly and file your
response letter, "tagged" as correspondence, via EDGAR. If you
do not agree with the comment, tell us why in your letter. Direct
any questions to me at (202) 942-1976. You may also contact me via
facsimile at (202) 942-9638. Please send all correspondence to us
at the following ZIP code: 20549-0303.
Sincerely,
Michael Pressman
Office of Mergers
and Acquisitions
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