SEC Company Response from LASER MASTER INTERNATIONAL INC (CIK 0000700892) — Nov 8, 2004
LASER MASTER INTERNATIONAL INC (CIK 0000700892)
Date: Nov. 8, 2004 · CIK: 0000700892 · Accession: 0001162327-04-000071
AI Filing Summary & Sentiment
Letter
Securities and Exchange Commission Washington, D.C. 20549 Form 8-K filed October 20, 2004 File No. 2-76262-NY
Re:
Dear Ms. Simpson
I have your comment letter of November 2, 2004.
We are a small company. Virtually all of the Company's dealings with Goldstein and Morris, our former auditors, were handled by two people -- my son Herschel and me. We talk to each other regularly. If there had been any disagreements with Goldstein and Morris they would have been discussed the disagreement with one of us, and both of us would know about the disagreement.
We provided a copy of our filing to Goldstein and Morris on the same day it was filed, and asked that firm to supply us with the Exhibit 16 letter. Our attorney followed up with a call to Goldstein and Morris the following business day. One of the Goldstein and Morris managing partners told our attorney that all of the auditors with SEC experience had left the firm, that the firm was abandoning its SEC practice, and that since the remaining auditors were not familiar enough with our account to provide the letter we had asked for, the firm would not be able to respond until they had received approval from their malpractice carrier. As a result, we do not know whether or when we will receive the letter. If we receive it we will promptly file it as an exhibit.
As to Comment 4, we understand the Company’s obligation to provide all information required by the Commission’s regulations, and to provide that information accurately and adequately. However, our attorneys have not been able to locate any Commission rule requiring us, in responding to staff comment letters, to waive defenses we may have against proceedings by the Commission or third parties. We understand that the American Bar Association’s Section of Business Law suggested in its comment letter of September 24, 2004 that any such requirement should be imposed only through the normal rule-making process. Our attorney will be happy to discuss this question with you should you so desire.
Please feel free to call me, or our attorney, David C. Thomas of Raice Paykin & Krieg LLP at 212-725-4423 if you have additional questions.
Sincerely,
/s/ Mendel Klein
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CORRESP 1 november4lettertosec.htm November 4, 2004 November 5, 2004 Ms. Effie Simpson Securities and Exchange Commission Washington, D.C. 20549 Re: Form 8-K filed October 20, 2004 File No. 2-76262-NY Dear Ms. Simpson I have your comment letter of November 2, 2004. We are a small company. Virtually all of the Company's dealings with Goldstein and Morris, our former auditors, were handled by two people -- my son Herschel and me. We talk to each other regularly. If there had been any disagreements with Goldstein and Morris they would have been discussed the disagreement with one of us, and both of us would know about the disagreement. We provided a copy of our filing to Goldstein and Morris on the same day it was filed, and asked that firm to supply us with the Exhibit 16 letter. Our attorney followed up with a call to Goldstein and Morris the following business day. One of the Goldstein and Morris managing partners told our attorney that all of the auditors with SEC experience had left the firm, that the firm was abandoning its SEC practice, and that since the remaining auditors were not familiar enough with our account to provide the letter we had asked for, the firm would not be able to respond until they had received approval from their malpractice carrier. As a result, we do not know whether or when we will receive the letter. If we receive it we will promptly file it as an exhibit. As to Comment 4, we understand the Company’s obligation to provide all information required by the Commission’s regulations, and to provide that information accurately and adequately. However, our attorneys have not been able to locate any Commission rule requiring us, in responding to staff comment letters, to waive defenses we may have against proceedings by the Commission or third parties. We understand that the American Bar Association’s Section of Business Law suggested in its comment letter of September 24, 2004 that any such requirement should be imposed only through the normal rule-making process. Our attorney will be happy to discuss this question with you should you so desire. Please feel free to call me, or our attorney, David C. Thomas of Raice Paykin & Krieg LLP at 212-725-4423 if you have additional questions. Sincerely, /s/ Mendel Klein Mendel Klein