SEC Comment Letter for RECOM MANAGED SYSTEMS INC DE — Feb 9, 2005
RECOM MANAGED SYSTEMS INC DE/ (CIK 0000810365)
Date: Feb. 9, 2005 · CIK: 0000810365 · Accession: 0000000000-05-006566
AI Filing Summary & Sentiment
File numbers found in text: 333-122296
Letter
February 9, 2005 Mail Stop 03-06 Marvin H. Fink Chief Executive Officer Recom Managed Systems 4705 Laurel Canyon Boulevard, Suite 203 Studio City, California 91607
Re: Recom Managed Systems, Inc. Amendment No. 1 to Registration Statement on Form SB-2 Filed January 26, 2005 File no. 333-122296
Dear Mr. Fink:
We have reviewed your amendment and have the following comment. Where indicated, we think you should revise your filing in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. You may decide it is appropriate to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
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 comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Fee Table 1. We note your changes to the fee table footnotes. Your references to "weighted average and other antidilution protective provisions" apparently could refer to transactions that are not considered "similar" transactions under Rule 416. Therefore, we reissue our previous comment.
As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Eduardo Aleman at (202) 824-5661 or me at (202) 824-5697 with any other questions.
Sincerely,
Russell Mancuso
Branch Chief
Show Raw Text
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<TEXT>
February 9, 2005
Mail Stop 03-06
Marvin H. Fink
Chief Executive Officer
Recom Managed Systems
4705 Laurel Canyon Boulevard, Suite 203
Studio City, California 91607
Re: Recom Managed Systems, Inc.
Amendment No. 1 to Registration Statement on Form SB-2
Filed January 26, 2005
File no. 333-122296
Dear Mr. Fink:
We have reviewed your amendment and have the following
comment.
Where indicated, we think you should revise your filing in
response
to this comment. If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation. You may
decide it is appropriate to provide us with supplemental
information
so we may better understand your disclosure. After reviewing this
information, we may or may not raise additional comments.
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 comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Fee Table
1. We note your changes to the fee table footnotes. Your
references
to "weighted average and other antidilution protective provisions"
apparently could refer to transactions that are not considered
"similar" transactions under Rule 416. Therefore, we reissue our
previous comment.
As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with
marked
copies of the amendment to expedite our review. Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review. Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.
You may contact Eduardo Aleman at (202) 824-5661 or me at
(202)
824-5697 with any other questions.
Sincerely,
Russell Mancuso
Branch Chief
cc (via facsimile): John M. Woodbury, Jr., Esq.
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Marvin H. Fink
Recom Managed Systems, Inc.
February 9, 2005
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