SEC Company Response from ORBIT E COMMERCE INC (CIK 0000071391) — Aug 30, 2005
ORBIT E COMMERCE INC (CIK 0000071391)
Date: Aug. 30, 2005 · CIK: 0000071391 · Accession: 0000945836-05-000041
AI Filing Summary & Sentiment
Referenced dates: August 16, 2005
Letter
Re: Orbit E-Commerce, Inc. (the "Company") File No. 1-03323
ORBIT E-COMMERCE, INC. 14845 YONGE STREET AURORA, ONTARIO L4G 6H8
August 30, 2005
Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, N.W. Mail Stop 3561 Washington, D.C. 20549 Attn: Nasreen Mohammed, Staff Accountant
Ladies and Gentlemen:
We are submitting this letter in response to the Commission's letter dated August 16, 2005. The comment numbers below refer to the paragraph numbers of the Commission's August 16, 2005 letter.
1. The Company acquired intangible rights and did not acquire an operating business and, therefore, did not account for the acquisition as the purchase of a business in accordance with SFAS 141. Although the Company acquired intangible rights, such rights were not and have not yet been put into operation.
2. Audited financial statements for the rights acquired will be prepared and will be included as part of the Company's audited financial statements which will be filed with the Company's Form 10-KSB for the fiscal year ended July 31, 2005.
In connection with our response to the Commission's comments, the Company acknowledges the following: (i) The Company is responsible for the adequacy and accuracy of the disclosure in the filings; (ii) 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 (iii) 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.
Please contact the undersigned with any further questions.
Very truly yours,
/s/ Douglas C. Lloyd
Douglas C. Lloyd
Chief Executive Officer
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
ORBIT E-COMMERCE, INC.
14845 YONGE STREET
AURORA, ONTARIO L4G 6H8
August 30, 2005
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Mail Stop 3561
Washington, D.C. 20549
Attn: Nasreen Mohammed, Staff Accountant
Re: Orbit E-Commerce, Inc. (the "Company")
File No. 1-03323
Ladies and Gentlemen:
We are submitting this letter in response to the
Commission's letter dated August 16, 2005. The comment numbers
below refer to the paragraph numbers of the Commission's August
16, 2005 letter.
1. The Company acquired intangible rights and did not
acquire an operating business and, therefore, did not account for
the acquisition as the purchase of a business in accordance with
SFAS 141. Although the Company acquired intangible rights, such
rights were not and have not yet been put into operation.
2. Audited financial statements for the rights acquired
will be prepared and will be included as part of the Company's
audited financial statements which will be filed with the
Company's Form 10-KSB for the fiscal year ended July 31, 2005.
In connection with our response to the Commission's
comments, the Company acknowledges the following: (i) The
Company is responsible for the adequacy and accuracy of the
disclosure in the filings; (ii) 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 (iii) 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.
Please contact the undersigned with any further questions.
Very truly yours,
/s/ Douglas C. Lloyd
Douglas C. Lloyd
Chief Executive Officer
</TEXT>
</DOCUMENT>