SEC Comment Letter for Cardiff Lexington Corp (CDIX) (CIK 0000811222) (CDIX) — Aug 14, 2013
Cardiff Lexington Corp (CDIX) (CIK 0000811222)
Date: Aug. 14, 2013 · CIK: 0000811222 · Accession: 0000000000-13-044611
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-49709
Referenced dates: July 19, 2013
Letter
August 13 , 2013 Via E-mail Daniel Thompson Chief Executive Officer Cardiff International, Inc. 2747 Paradise Road Unit 1103 Las Vegas, NV 89109
Re: Cardiff International, Inc. Revised Information Statement on Schedule 14C Filed August 2, 2013 File No. 000-49709
Dear Mr. Thompson :
We have reviewed your amended filing an d have the following comment . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Where we refer to prior comments we are referring to our letter dated July 19, 2013
Please respond to this l etter within ten business days by providing the requested information, or by advising us when you will prov ide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information yo u provide in response to these comments, we may have additional comments.
General
1. We have reviewed your response to prior comment 1 and your corresponding revised discl osures. I t appears that you may have engaged in a soli citation rendering Schedule 14C unavailable to you. Please tell us in material detail the sequence of events through which you obtained the consents from the shareholders listed on page 2, and describe each shareholders’ relationship to the company . If you are unable to provide us with an analysis of whether you engaged in a solicitation in obtaining the consents, please file a proxy statement on Schedule 14A.
Daniel Thompson Cardiff International, Inc. August 13 , 2013 Page 2
Please contact Ivan Griswold at (202) 551 -3853 or, in his absence, me at (202) 551 -3457 with any questions.
Sincerely,
/s/ Maryse Mills -Apenteng
Show Raw Text
August 13 , 2013
Via E-mail
Daniel Thompson
Chief Executive Officer
Cardiff International, Inc.
2747 Paradise Road Unit 1103
Las Vegas, NV 89109
Re: Cardiff International, Inc.
Revised Information Statement on Schedule 14C
Filed August 2, 2013
File No. 000-49709
Dear Mr. Thompson :
We have reviewed your amended filing an d have the following comment . In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure. Where we refer to prior comments we are referring to our letter dated July 19, 2013
Please respond to this l etter within ten business days by providing the requested
information, or by advising us when you will prov ide the requested response. If you do not
believe our comments apply to your facts and circumstances or do not believe an amendment is
appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information yo u provide in
response to these comments, we may have additional comments.
General
1. We have reviewed your response to prior comment 1 and your corresponding revised
discl osures. I t appears that you may have engaged in a soli citation rendering Schedule
14C unavailable to you. Please tell us in material detail the sequence of events through
which you obtained the consents from the shareholders listed on page 2, and describe
each shareholders’ relationship to the company . If you are unable to provide us with an
analysis of whether you engaged in a solicitation in obtaining the consents, please file a
proxy statement on Schedule 14A.
Daniel Thompson
Cardiff International, Inc.
August 13 , 2013
Page 2
Please contact Ivan Griswold at (202) 551 -3853 or, in his absence, me at (202) 551 -3457
with any questions.
Sincerely,
/s/ Maryse Mills -Apenteng
Maryse Mills -Apenteng
Special Counsel