SEC Comment Letter for Nayna Networks, Inc. (CIK 0000769591) — Apr 20, 2005
Nayna Networks, Inc. (CIK 0000769591)
Date: April 20, 2005 · CIK: 0000769591 · Accession: 0000000000-05-019408
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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April 20, 2005
Mail Stop 05-11
Naveen Bisht, Chief Executive Officer
Rescon Technology Corporation
180 Rose Orchard Way
San Jose, CA 95134
Re: Form 8-K 4.01 filed April 20, 2005
File No. 0-13822
Dear Mr. Bisht:
We have reviewed your filing and have the following comment.
Where indicated, we think you should revise your document in
response
to the comment. If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
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 comment or any other aspect
of
our review. Feel free to call the applicable staff person at the
telephone number listed at the end of this letter.
Please file a letter from your former accountant stating
whether the accountant agrees with your Item 304 disclosures, or
the
extent to which the accountant does not agree. Please refer to
Item
304(a)(3) of Regulation S-B.
Please file your supplemental response and amendment via
EDGAR
in response to these comments within 5 business days after the
date
of this letter. Please contact the staff immediately if you
require
longer than 5 business days to respond.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the registrant and its management are
in
possession of all facts relating to a registrant`s disclosure,
they
are responsible for the accuracy and adequacy of the disclosures
they
have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the registrant acknowledging that:
* the registrant 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 registrant 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
Direct any questions regarding this letter to Babette Cooper
at
202-824-5069.
Sincerely,
Babette Cooper
Staff Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306
DIVISION OF
CORPORATION FINANCE
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