SEC Comment Letter for CIRTRAN CORP (CIRX) (CIK 0000813716) (CIRX) — Feb 15, 2007
CIRTRAN CORP (CIRX) (CIK 0000813716)
Date: Feb. 15, 2007 · CIK: 0000813716 · Accession: 0000000000-07-008246
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 6010 February 15, 2007 Iehab Hawatmeh President and Director CirTran Corporation 4125 South 6000 West West Valley City, Utah 84128
Re: CirTran Corporation Preliminary Information Statement Filed February 7, 2007 File No. 0-49654
Dear Mr. Hawatmeh:
We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise 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 detailed as necess ary in your explanation. In some of our comments, we may ask you to pr ovide us with information so we may better understand your disclosure. After reviewing this information, we may 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 ove rall disclosure in your filing. We look forward to working with you in these re spects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to ca ll us at the telephone numbers listed at the end of this letter.
General 1. It appears that your so licitation to obtain the consents of holders of a majority of your shares did not comply with Rule 14a-3(a) of Regulation 14A. Please provide your analysis to support your position that th e consents were obtained in compliance with the proxy rules.
Board of Directors Meeti ngs, Committees and Director Compensation, page 17 2. Please update this section to in clude required disclosure for th e fiscal year ended December 31, 2006 and the new executive compensation disc losure rules. See Release No. 33-8765, which is available on our website.
CirTran Corporation February 15, 2007 Page 2 As appropriate, please revise your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the revised filing to expedite our review. Please furnish a cover letter with your amendment that keys your res ponses to our comments and provide s any requested information. Detailed cover letters greatly facilitate our revi ew. Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the proxy statement to be certain that the fi ling includes all information required under the Securities Exchange Act of 1934 and that they have provided all informati on investors require for an informed investment decision. Since the comp any and its management are in possession of all facts relating to a company’s disclosure, they ar e responsible for the accur acy and adequacy of the disclosures they have made.
In connection with responding to our comme nts, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
staff comments or changes to disclosure in re sponse 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.
In addition, please be advised th at the Division of Enforcement has access to all information you provide to the staff of the Division of Corpor ation Finance in our review of your filing or in response to our comments on your filing.
Please contact Tom Jones at (202) 551-3602 or me at (202) 551-3800 if you have questions.
S i n c e r e l y ,
Peggy Fisher A s s i s t a n t D i r e c t o r
Show Raw Text
Mail Stop 6010
February 15, 2007
Iehab Hawatmeh
President and Director
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128
Re: CirTran Corporation
Preliminary Information Statement
Filed February 7, 2007
File No. 0-49654
Dear Mr. Hawatmeh:
We have limited our review of your filing to those issues we have addressed in our
comments. Where indicated, we think you should revise 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 detailed as necess ary in your explanation.
In some of our comments, we may ask you to pr ovide us with information so we may better
understand your disclosure. After reviewing this information, we may 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 ove rall disclosure in your filing.
We look forward to working with you in these re spects. We welcome any questions you may have
about our comments or on any other aspect of our review. Feel free to ca ll us at the telephone
numbers listed at the end of this letter.
General
1. It appears that your so licitation to obtain the consents of holders of a majority of your
shares did not comply with Rule 14a-3(a) of Regulation 14A. Please provide your analysis
to support your position that th e consents were obtained in compliance with the proxy rules.
Board of Directors Meeti ngs, Committees and Director Compensation, page 17
2. Please update this section to in clude required disclosure for th e fiscal year ended December
31, 2006 and the new executive compensation disc losure rules. See Release No. 33-8765,
which is available on our website.
CirTran Corporation
February 15, 2007
Page 2
As appropriate, please revise your filing and respond to these comments within 10 business
days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the revised filing to expedite our review. Please furnish a cover letter with your amendment that keys your res ponses to our comments and provide s any requested information.
Detailed cover letters greatly facilitate our revi ew. Please understand that we may have additional
comments after reviewing your amendmen t and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
the proxy statement to be certain that the fi ling includes all information required under the
Securities Exchange Act of 1934 and that they have provided all informati on investors require for
an informed investment decision. Since the comp any and its management are in possession of all
facts relating to a company’s disclosure, they ar e responsible for the accur acy and adequacy of the
disclosures they have made.
In connection with responding to our comme nts, please provide, in writing, a statement
from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
staff comments or changes to disclosure in re sponse 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.
In addition, please be advised th at the Division of Enforcement has access to all information
you provide to the staff of the Division of Corpor ation Finance in our review of your filing or in
response to our comments on your filing.
Please contact Tom Jones at (202) 551-3602 or me at (202) 551-3800 if you have questions.
S i n c e r e l y ,
Peggy Fisher
A s s i s t a n t D i r e c t o r