SEC Company Response from Gener8xion Entertainment, Inc. (CIK 0000803034) — May 23, 2005
Gener8xion Entertainment, Inc. (CIK 0000803034)
Date: May 23, 2005 · CIK: 0000803034 · Accession: 0000950136-05-003013
AI Filing Summary & Sentiment
File numbers found in text: 000-15382
Letter
ON GENER8XION ENTERTAINMENT LETTERHEAD May 23, 2005 Mr. Joseph Forti Senior Assistant Chief Accountant Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549-0305
Re: Gener8xion Entertainment, Inc. Letter of May 4, 2005 Commission File Number: 000-15382
Dear Mr. Forti:
The following are in response to your above referenced letter we received regarding your review of our April 14, 2005 letter. Our response is numbered to coincide with the number of your comment.
1. The officers and consultant (there were no other employees) were not serving under employment or other agreements.
2. We are currently preparing Form 10-QSB for the quarter ended April 30, 2005 and expect to file by the due date. We will revise our disclosures in the "Management's Discussion and Analysis or Plan of Operations" section to discuss the matters accounting policies and estimates we consider critical.
3. Our Form 10-QSB for the quarter ended April 30, 2005 will include appropriate disclosure regarding the source of revenue. Further, required related party disclosures will also be included.
4. We have acquired the distribution rights of "One Night with the King" without any further required investment by the Company. One Night With The King, Inc. (the production company) at the time of the purchase of the distribution rights, was twenty days short of completing principal photography. The production company was obligated to complete principal photography, post production, and prints and advertising, and any other costs associated with the completion of the film prior to distribution. The Company is not financially obligated in any way to the completion process of the film.
5. The transaction wherein we issued shares was for the distribution and other rights and the furtherance of the new business with Mr. Crouch as the Chief Executive Officer. The employment of Mr. Crouch would not have occurred separately from the acquisition of the rights. Mr. Crouch's employment arrangement provides for appropriate cash compensation for his services. The negotiations were based the assets acquired for the shares issued and did not contemplate any issuance of shares for his employment. Accordingly, we believe that our accounting for the transaction is appropriate.
We understand 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 by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
Marilyn Beaubien
Chief Financial Officer
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ON GENER8XION ENTERTAINMENT LETTERHEAD
May 23, 2005
Mr. Joseph Forti
Senior Assistant Chief Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549-0305
Re: Gener8xion Entertainment, Inc.
Letter of May 4, 2005
Commission File Number: 000-15382
Dear Mr. Forti:
The following are in response to your above referenced letter we received
regarding your review of our April 14, 2005 letter. Our response is numbered to
coincide with the number of your comment.
1. The officers and consultant (there were no other employees) were not
serving under employment or other agreements.
2. We are currently preparing Form 10-QSB for the quarter ended April 30, 2005
and expect to file by the due date. We will revise our disclosures in the
"Management's Discussion and Analysis or Plan of Operations" section to
discuss the matters accounting policies and estimates we consider critical.
3. Our Form 10-QSB for the quarter ended April 30, 2005 will include
appropriate disclosure regarding the source of revenue. Further, required
related party disclosures will also be included.
4. We have acquired the distribution rights of "One Night with the King"
without any further required investment by the Company. One Night With The
King, Inc. (the production company) at the time of the purchase of the
distribution rights, was twenty days short of completing principal
photography. The production company was obligated to complete principal
photography, post production, and prints and advertising, and any other
costs associated with the completion of the film prior to distribution. The
Company is not financially obligated in any way to the completion process
of the film.
5. The transaction wherein we issued shares was for the distribution and other
rights and the furtherance of the new business with Mr. Crouch as the Chief
Executive Officer. The employment of Mr. Crouch would not have occurred
separately from the acquisition of the rights. Mr. Crouch's employment
arrangement provides for appropriate cash compensation for his services.
The negotiations were based the assets acquired for the shares issued and
did not contemplate any issuance of shares for his employment. Accordingly,
we believe that our accounting for the transaction is appropriate.
We understand 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 by the Commission or any person under
the federal securities laws of the United States.
Very truly yours,
Marilyn Beaubien
Chief Financial Officer