SEC Company Response from VERSO TECHNOLOGIES INC (CIK 0000797448) — Nov 19, 2004
VERSO TECHNOLOGIES INC (CIK 0000797448)
Date: Nov. 19, 2004 · CIK: 0000797448 · Accession: 0000950144-04-011415
AI Filing Summary & Sentiment
File numbers found in text: 000-22190
Letter
VERSO TECHNOLOGIES, INC.
WRITER’S DIRECT DIAL NUMBER
(404) 420-4646
WRITER’S E-MAIL ADDRESS
LAG@RH-LAW.COM
November 19, 2004
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Maryse Mills-Apenteng, Esq.
Re:
Verso Technologies, Inc.
Preliminary Schedule 14A Filed on November 9, 2004
File No. 000-22190
Ladies and Gentlemen:
On behalf of Verso Technologies, Inc. (the “Company”) and pursuant to our conversations with the Staff, we transmit herewith for filing a conformed copy of the Company’s Definitive Schedule 14A marked to show changes in accordance with Rule 310 of Regulation S-T made to the Company’s Preliminary Schedule 14A filed on November 9, 2004.
The Definitive Schedule 14A responds to comments of the Staff contained in the letter from Barbara C. Jacobs to Steven A. Odom dated November 18, 2004. In the interested of clarity, defined terms not otherwise defined in this letter are as defined in Definitive Schedule 14A. For the Staff’s convenience, the numbered paragraphs below correspond to the paragraph numbers in the Staff’s November 18, 2004 comment letter.
1.
As the Staff requested, we have revised the disclosure regarding the Incentive Plan to state that the Company does not have any plans, proposals or arrangements, written or otherwise, to issue any awards under the Incentive Plan.
2.
As the Staff requested, we have revised the disclosure relating to the Incentive Plan to state that the description of the Incentive Plan provides a materially complete summary of the Incentive Plan and to eliminate statements that the description of the Incentive Plan does not purport to be complete and is qualified in its entirety by reference to the full text of the Incentive Plan.
Securities and Exchange Commission
November 19, 2004
Page 2
The other changes made to the Preliminary Schedule 14A reflect updating of, and certain other immaterial revisions to, the disclosure contained therein. Any comments or questions regarding this filing should be directed to the undersigned at Rogers & Hardin LLP, 2700 International Tower, 229 Peachtree Street, N.E., Atlanta, Georgia 30303, telephone (404) 420-4646, facsimile (404) 525-2224. We appreciate your prompt attention to this matter.
Sincerely,
/s/ Lori A. Gelchion
Show Raw Text
CORRESP
1
filename1.htm
VERSO TECHNOLOGIES, INC.
WRITER’S DIRECT DIAL NUMBER
(404) 420-4646
WRITER’S E-MAIL ADDRESS
LAG@RH-LAW.COM
November 19, 2004
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Maryse Mills-Apenteng, Esq.
Re:
Verso Technologies, Inc.
Preliminary Schedule 14A Filed on November 9, 2004
File No. 000-22190
Ladies and Gentlemen:
On
behalf of Verso Technologies, Inc. (the “Company”) and
pursuant to our conversations with the Staff, we transmit herewith
for filing a conformed copy of the Company’s Definitive Schedule
14A marked to show changes in accordance with Rule 310 of
Regulation S-T made to the Company’s Preliminary Schedule
14A filed on November 9, 2004.
The Definitive Schedule 14A responds to comments of the Staff contained in the letter from Barbara C. Jacobs to
Steven A. Odom dated November 18, 2004. In the interested of clarity, defined
terms not otherwise defined in this letter are as defined in
Definitive Schedule 14A. For the Staff’s convenience, the numbered paragraphs below correspond to the
paragraph numbers in the Staff’s November 18, 2004 comment letter.
1.
As the Staff requested, we have revised the disclosure
regarding the Incentive Plan to state that the Company does not have
any plans, proposals or arrangements, written or otherwise, to issue
any awards under the Incentive Plan.
2.
As the Staff requested, we have revised the disclosure
relating to the Incentive Plan to state that the description of the
Incentive Plan provides a materially complete summary of the
Incentive Plan and to eliminate statements that the description of
the Incentive Plan does not purport to be complete and is qualified
in its entirety by reference to the full text of the Incentive Plan.
Securities and Exchange Commission
November 19, 2004
Page 2
The
other changes made to the Preliminary Schedule 14A reflect
updating of, and certain other immaterial revisions to, the disclosure
contained therein. Any comments or questions regarding this
filing should be directed to the undersigned at Rogers & Hardin LLP, 2700
International Tower, 229 Peachtree Street, N.E., Atlanta, Georgia 30303,
telephone (404) 420-4646, facsimile (404) 525-2224. We appreciate your prompt
attention to this matter.
Sincerely,
/s/ Lori A. Gelchion
Lori A. Gelchion
Enclosure