SEC Company Response from SOLIGENIX, INC. (SNGX) (CIK 0000812796) (SNGX) — Jan 25, 2007
SOLIGENIX, INC. (SNGX) (CIK 0000812796)
Date: Jan. 25, 2007 · CIK: 0000812796 · Accession: 0000812796-07-000006
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 5, 2006
Letter
Division of Corporation Finance United States Securities and Exchange Commission F Street, NE Washington, D.C. 20549 RE: Review of Filings and comments related to Form 10KSB for the Fiscal Year Ended December 31, 2005 and Form 10QSB for the Fiscal Quarter Ended June 30, 2006.
Dear Ms. Buckner:
This letter is in response to the conference call we had on January 16, 2007 at 11:45 am concerning comment 5 of your letter dated December 5, 2006.
We acknowledge that the variable accounting treatment of the stock options issued in December 2004 may have been misapplied and that the $285,000 expense taken in 2004 should not have been recorded. With respect to FIN 28 we conclude that since the options were not available at the time they were granted a grant date did not exist so it was not necessary to record this expense. We will ensure that all future applications of FIN 28 and accounting policies with respect to stock options and grant dates will be accurately reflected. Our accounting policy in all future financial statements will reflect this treatment of stock options.
In connection with our responses to your comments, we acknowledge 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 utilize staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you should have any further questions please do not hesitate to call me at 786-425-3848.
Sincerely,
/s/Evan
Myrianthopoulos
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CORRESP
1
filename1.htm
DOR
BioPharma, Inc.
1101
Brickell Avenue
701-S
Miami,
FL
33131
January
25, 2007
SENT
VIA EDGAR
Amy
C. Bruckner
Staff
Accountant
Division
of Corporation Finance
United
States Securities and Exchange Commission
100
F
Street, NE
Washington,
D.C. 20549
RE:
Review of Filings and comments related to Form 10KSB for the Fiscal Year Ended
December 31, 2005 and Form 10QSB for the Fiscal Quarter Ended June 30, 2006.
Dear
Ms.
Buckner:
This
letter is in response to the conference call we had on January 16, 2007 at
11:45
am concerning comment 5 of your letter dated December 5, 2006.
We
acknowledge that the variable accounting treatment of the stock options issued
in December 2004 may have been misapplied and that the $285,000 expense taken
in
2004 should not have been recorded. With respect to FIN 28 we conclude that
since the options were not available at the time they were granted a grant
date
did not exist so it was not necessary to record this expense. We will ensure
that all future applications of FIN 28 and accounting policies with respect
to
stock options and grant dates will be accurately reflected. Our accounting
policy in all future financial statements will reflect this treatment of stock
options.
In
connection with our responses to your comments, we acknowledge
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 utilize staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
If
you
should have any further questions please do not hesitate to call me at
786-425-3848.
Sincerely,
/s/Evan
Myrianthopoulos
Evan
Myrianthopoulos
Chief
Financial Officer
DOR
BioPharma, Inc.
MD/SEC/2Comment