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SEC Comment Letter for Baymark Technologies, Inc. (CIK 0000352912) — Mar 31, 2005

Baymark Technologies, Inc. (CIK 0000352912)
Date: March 31, 2005 · CIK: 0000352912 · Accession: 0000000000-05-015607

AI Filing Summary & Sentiment

Date
March 30, 2005
Author
Linda Cvrkel
Form
UPLOAD
Company
Baymark Technologies, Inc. (CIK 0000352912)

Letter

March 30, 2005 Via Fax & U.S. Mail Mr. Jon Elliott President and Chief Executive Officer Baymark Technologies, Inc. 7609 Ralston Road Arvada, Colorado 80002

RE: Baymark Technologies, Inc. Form 10-KSB for the Fiscal Year Ended July 31, 2004 File No. 0-10315

Dear Mr. Elliott:

Based upon an examination restricted solely to considerations of the Financial Statements and Management`s Discussion and Analysis, we have the following comment on the above-referenced document. Where indicated, we think you should revise your future filings in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your response. We have also asked you to provide us with supplemental information so we may better understand your disclosure. 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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

* * * * *

Please respond to confirm that such comments will be complied with, or, if certain of the comments are deemed inappropriate, advise us of the reason thereof. Please respond within fifteen business days.

Financial Statements Note 4. Capital Stock Transactions

Supplementally tell us, and clarify in the notes to your financial statements in future filings, how you value shares issued for services. As part of your response, please indicate how the treatment used complies with the requirements of APB 25, SFAS No.123, EITF 96-18 or other applicable accounting literature. Additionally, to the extent that any discounts from market value were used in valuing shares issued for services or other non-cash consideration, please explain the basis or rationale for the discounts used.

Closing

You may contact Katherine Mathis at (202) 942-1994 or, in her absence, me at (202) 942-1936, if you have any questions regarding the comments above. Please contact Max Webb, Assistant Director, at (202) 942-1850 with any other questions.

Sincerely,
Linda Cvrkel
Branch Chief

Show Raw Text
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									March 30, 2005

Via Fax & U.S. Mail

Mr. Jon Elliott
President and Chief  Executive Officer
Baymark Technologies, Inc.
7609 Ralston Road
Arvada, Colorado  80002

RE: 	Baymark Technologies, Inc.
	Form 10-KSB for the Fiscal Year Ended July 31, 2004
	File No. 0-10315

Dear Mr. Elliott:

	Based upon an examination restricted solely to considerations
of
the Financial Statements and Management`s Discussion and Analysis,
we
have the following comment on the above-referenced document.
Where
indicated, we think you should revise your future filings in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your response.
We have also asked you to provide us with supplemental information
so
we may better understand your disclosure.  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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

* * * * *

	Please respond to confirm that such comments will be complied
with, or, if certain of the comments are deemed inappropriate,
advise
us of the reason thereof.  Please respond within fifteen business
days.

Financial Statements
Note 4. Capital Stock Transactions

Supplementally tell us, and clarify in the notes to your financial
statements in future filings, how you value shares issued for
services.  As part of your response, please indicate how the
treatment used complies with the requirements of APB 25, SFAS
No.123,
EITF 96-18 or other applicable accounting literature.
Additionally,
to the extent that any discounts from market value were used in
valuing shares issued for services or other non-cash
consideration,
please explain the basis or rationale for the discounts used.

Closing

You may contact Katherine Mathis at (202) 942-1994 or, in her
absence, me at (202) 942-1936, if you have any questions regarding
the comments above.  Please contact Max Webb, Assistant Director,
at
(202) 942-1850 with any other questions.

Sincerely,

							Linda Cvrkel
							Branch Chief

Via facsimile:  (303) 431-1567
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Mr.  Jon Elliott
Baymark Technologies, Inc.
March 30, 2005
Page 1

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