SEC Company Response from TOMI Environmental Solutions, Inc. (TOMZ) (CIK 0000314227) (TOMZ) — Jun 4, 2009
TOMI Environmental Solutions, Inc. (TOMZ) (CIK 0000314227)
Date: June 4, 2009 · CIK: 0000314227 · Accession: 0001170022-09-000011
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 14, 2009
Letter
HAROLD W. PAUL, LLC ATTORNEY AT LAW PO Box 33812 Santa Fe, NM 87594 (505) 983-2794 Fax (866) 644-7615 June 3, 2009 Mr. Howard Efron Securities and Exchange Commission Mail Stop 4561 100 F Street, NE Washington, DC 20549
Re: Ozone Man, Inc. Form 10-K For the year ended December 31, 2008 File No. 0-09908
Dear Mr. Efron:
We represent TOMI Environmental Solutions, Inc., formerly The Ozone Man, Inc. Our client has forwarded to us your letter dated May 14, 2009 and authorized us to reply.
Supplementally, we advise as follows:
Form 10-K for the year Ended December 31, 2008 ----------------------------------------------
Financial Statements --------------------
Note 4 - Intangible Assets, page F-12 -------------------------------------
1. Management's basis for determining the deferral of amortization on the Company's intangible assets is that the benefit derived from such intangible assets will not occur until such time as when the Company commences principal operations. The Company will amortize its intangibles over their estimated useful lives, based on an analysis of pertinent factors, including the expected use of the asset by the entity (SFAS 142 11a).
Note 13 - Forgiveness of Debt, page F-17 ----------------------------------------
2. As a matter of clarification, $25,000 was forgiven. The obligation of the Company for past due legal services was $50,000. $25,000 was forgiven and the balance was represented by the convertible promissory note.
<PAGE>
HAROLD W. PAUL, LLC
Mr. Howard Efron Securities and Exchange Commission June 3, 2009 Page Two
Exhibits 31.1 and 31.2 ----------------------
3. The staff's comment regarding certain modifications to the certifications is noted and we represent that all future filings commencing with the Company's 10-Q for the period ending June 30, 2009 will conform to the exact form set forth in Item 601(b)(31) of Regulation S-K.
The Company acknowledges that:
. the company is responsible for the adequacy and accuracy of the disclosure in the filing;
. staff comments or changes to disclosure in response to staff comments 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.
Please do not hesitate to contact the undersigned if you have any further comments or questions.
Sincerely,
/s/ HAROLD W. PAUL, LLC
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HAROLD W. PAUL, LLC
ATTORNEY AT LAW
PO Box 33812
Santa Fe, NM 87594
(505) 983-2794
Fax (866) 644-7615
June 3, 2009
Mr. Howard Efron
Securities and Exchange Commission
Mail Stop 4561
100 F Street, NE
Washington, DC 20549
Re: Ozone Man, Inc.
Form 10-K For the year ended December 31, 2008
File No. 0-09908
Dear Mr. Efron:
We represent TOMI Environmental Solutions, Inc., formerly The Ozone Man,
Inc. Our client has forwarded to us your letter dated May 14, 2009 and
authorized us to reply.
Supplementally, we advise as follows:
Form 10-K for the year Ended December 31, 2008
----------------------------------------------
Financial Statements
--------------------
Note 4 - Intangible Assets, page F-12
-------------------------------------
1. Management's basis for determining the deferral of amortization on the
Company's intangible assets is that the benefit derived from such
intangible assets will not occur until such time as when the Company
commences principal operations. The Company will amortize its
intangibles over their estimated useful lives, based on an analysis of
pertinent factors, including the expected use of the asset by the
entity (SFAS 142 11a).
Note 13 - Forgiveness of Debt, page F-17
----------------------------------------
2. As a matter of clarification, $25,000 was forgiven. The obligation of
the Company for past due legal services was $50,000. $25,000 was
forgiven and the balance was represented by the convertible promissory
note.
<PAGE>
HAROLD W. PAUL, LLC
Mr. Howard Efron
Securities and Exchange Commission
June 3, 2009
Page Two
Exhibits 31.1 and 31.2
----------------------
3. The staff's comment regarding certain modifications to the
certifications is noted and we represent that all future filings
commencing with the Company's 10-Q for the period ending June 30, 2009
will conform to the exact form set forth in Item 601(b)(31) of
Regulation S-K.
The Company acknowledges that:
. the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
. staff comments or changes to disclosure in response to staff comments
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.
Please do not hesitate to contact the undersigned if you have any further
comments or questions.
Sincerely,
/s/ HAROLD W. PAUL, LLC
/sl HAROLD W. PAUL, LLC
cc: Halden Shane
TOMI Environmental Solutions, Inc.
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