SEC Comment Letter for Viewbix Inc. (VBIX) (CIK 0000797542) (QXL) — Jul 17, 2008
Viewbix Inc. (VBIX) (CIK 0000797542)
Date: July 17, 2008 · CIK: 0000797542 · Accession: 0000000000-08-035467
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-15746
Letter
Mail Stop 3561 July 17, 2008 Ivo Heiden Chief Executive Officer Zaxis International Inc. 6399 Wilshire Boulevard, Suite 1019 Los Angeles, CA 90048
Re: Zaxis International Inc. Form 10-KSB for Fiscal Year Ended December 31, 2007 Filed March 26, 2008 File No. 000-15746
Dear Ivo Heiden: We have reviewed your filing and have the following comments. Where indicated, we think you should re vise your document 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 deta iled as necessary in your explanation. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments. It does not appear th at your management has perfor med its assessment of internal control over financial reporting as of Decemb er 31, 2007. Since you were required to file or filed an annual report for the prior fiscal year, it appears you are required to report on your management’s assessment of intern al control over financial reporting. If your management has not yet performed its assessment, we ask that you complete your evaluation and amend your fili ng within 30 calendar days to provide the required management's report on internal control over financia l reporting. In performing your evaluation, you may find the following documents helpful: the Commission’s release Amendments to Rules Regarding Management’s Report on Internal Control Over Financial Reporting (Securities Act Release 8809/Financial Reporting Release 76). You can find this release at: http://www.sec.gov/rules/final/2007/33-8809.pdf ;
Ivo Heiden Zaxis International Inc. July 17, 2008 Page 2
the Commission’s release Commission Guidance Regarding Management’s Report on Internal Control Over Financ ial Reporting Under Section 13(a) or 15(d) of the Securities Exchange Act of 1934 (Securities Act Release 8010/Financial Reporting Release 77). You can find this release at http://sec.gov/rule s/interp/2007/33-8810.pdf ; and
the “Sarbanes-Oxley Section 404 – A Guid e for Small Business” brochure at: (http://www.sec.gov/info/smallbus/404guide.shtml ).
In addition, please consider whether manage ment’s failure to perform or complete its report on internal control over financial reporting impacts its conclusions regarding the effectiveness of your disclosu re controls and procedures as of the end of the fiscal year covered by the report and revise your disclosure as appropriate. Please note that the failure to perform management’s assessment adversely affects the company’s and its shareholders ability to avail themselves of rules and forms that are predicated on the current or timely fili ng of Exchange Act reports. For further information regarding these impacts, please see Compliance and Disclosure Interpretation 115.02, which you can find at http://www.sec.gov/divisions /corpfin/guidance/regs- kinterp.htm . Please understand that the purpose of our re view 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 ou r comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. We urge all persons who are responsibl e for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’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 company acknowledging 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
Ivo Heiden Zaxis International Inc. July 17, 2008 Page 3
by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Di vision of Enforcement has access to all information you provide to the staff of the Divi sion of Corporation Finance in our review of your filing or in response to our comments on your filing. You may contact Ethan Horowitz, Staff Accountant, at (202) 551-3311 or me at (202) 551-3390 if you have questions regard ing comments on the financial statements and related matters. Sincerely, Brian K. Bhandari Branch Chief Office of Beverages, Apparel and Health Care Services
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Mail Stop 3561 July 17, 2008 Ivo Heiden Chief Executive Officer Zaxis International Inc. 6399 Wilshire Boulevard, Suite 1019 Los Angeles, CA 90048 Re: Zaxis International Inc. Form 10-KSB for Fiscal Year Ended December 31, 2007 Filed March 26, 2008 File No. 000-15746 Dear Ivo Heiden: We have reviewed your filing and have the following comments. Where indicated, we think you should re vise your document 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 deta iled as necessary in your explanation. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments. It does not appear th at your management has perfor med its assessment of internal control over financial reporting as of Decemb er 31, 2007. Since you were required to file or filed an annual report for the prior fiscal year, it appears you are required to report on your management’s assessment of intern al control over financial reporting. If your management has not yet performed its assessment, we ask that you complete your evaluation and amend your fili ng within 30 calendar days to provide the required management's report on internal control over financia l reporting. In performing your evaluation, you may find the following documents helpful: the Commission’s release Amendments to Rules Regarding Management’s Report on Internal Control Over Financial Reporting (Securities Act Release 8809/Financial Reporting Release 76). You can find this release at: http://www.sec.gov/rules/final/2007/33-8809.pdf ; Ivo Heiden Zaxis International Inc. July 17, 2008 Page 2 the Commission’s release Commission Guidance Regarding Management’s Report on Internal Control Over Financ ial Reporting Under Section 13(a) or 15(d) of the Securities Exchange Act of 1934 (Securities Act Release 8010/Financial Reporting Release 77). You can find this release at http://sec.gov/rule s/interp/2007/33-8810.pdf ; and the “Sarbanes-Oxley Section 404 – A Guid e for Small Business” brochure at: (http://www.sec.gov/info/smallbus/404guide.shtml ). In addition, please consider whether manage ment’s failure to perform or complete its report on internal control over financial reporting impacts its conclusions regarding the effectiveness of your disclosu re controls and procedures as of the end of the fiscal year covered by the report and revise your disclosure as appropriate. Please note that the failure to perform management’s assessment adversely affects the company’s and its shareholders ability to avail themselves of rules and forms that are predicated on the current or timely fili ng of Exchange Act reports. For further information regarding these impacts, please see Compliance and Disclosure Interpretation 115.02, which you can find at http://www.sec.gov/divisions /corpfin/guidance/regs- kinterp.htm . Please understand that the purpose of our re view 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 ou r comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. We urge all persons who are responsibl e for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’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 company acknowledging 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 Ivo Heiden Zaxis International Inc. July 17, 2008 Page 3 by the Commission or any person under the federal securities laws of the United States. In addition, please be advised that the Di vision of Enforcement has access to all information you provide to the staff of the Divi sion of Corporation Finance in our review of your filing or in response to our comments on your filing. You may contact Ethan Horowitz, Staff Accountant, at (202) 551-3311 or me at (202) 551-3390 if you have questions regard ing comments on the financial statements and related matters. Sincerely, Brian K. Bhandari Branch Chief Office of Beverages, Apparel and Health Care Services