SEC Comment Letter for CIRTRAN CORP (CIRX) (CIK 0000813716) (CIRX) — Mar 2, 2007
CIRTRAN CORP (CIRX) (CIK 0000813716)
Date: March 2, 2007 · CIK: 0000813716 · Accession: 0000000000-07-010889
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 6010 March 1, 2007 Iehab Hawatmeh President and Director CirTran Corporation 4125 South 6000 West West Valley City, Utah 84128
Re: CirTran Corporation Revised Preliminary Information Statement Filed February 26, 2007 File No. 0-49654
Dear Mr. Hawatmeh:
We have limited our review of your filing to those issues we have addressed in our comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, we will cons ider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation.
Please understand that the purpose of our re view 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.
Special Factors Regarding the Transaction, page 16 1. We note your response to comment 1. It appears that you have solicited consents in violation of Rule 14a-3 to the federa l proxy rules, which require you to furnish a “publicly filed preliminary or definitiv e written proxy statement” in connection with the solicitation of proxies (which includes consents), except in narrow circumstances. While it is true that Regulation 14C provides for the use of an information statement, that use is predicat ed on the initial solicitation of consents in a manner that is consistent with the federal proxy rules. See Rules 14a-2 and 14a-3 and the definitions of “solicitat ion” and “proxy.” Please advise why you believe you are in compliance with the so licitation requirements of the federal proxy rules, or explain what steps you w ill take to correct your noncompliance.
CirTran Corporation March 1, 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 responses to our comments and provides any requested information. Detailed co ver letters greatly faci litate our review. Please understand that we may have addi tional comments after reviewing your amendment and responses to our comments.
Please contact Tom Jones at (202) 551- 3602 or me at (202) 551-3800 with any 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
March 1, 2007
Iehab Hawatmeh
President and Director
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128
Re: CirTran Corporation
Revised Preliminary Information Statement
Filed February 26, 2007
File No. 0-49654
Dear Mr. Hawatmeh:
We have limited our review of your filing to those issues we have addressed in
our comment. Where indicated, we think you should revise your document in response to
this comment. If you disagree, we will cons ider your explanation as to why our comment
is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your
explanation.
Please understand that the purpose of our re view 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.
Special Factors Regarding the Transaction, page 16
1. We note your response to comment 1. It appears that you have solicited consents
in violation of Rule 14a-3 to the federa l proxy rules, which require you to furnish
a “publicly filed preliminary or definitiv e written proxy statement” in connection
with the solicitation of proxies (which includes consents), except in narrow
circumstances. While it is true that Regulation 14C provides for the use of an
information statement, that use is predicat ed on the initial solicitation of consents
in a manner that is consistent with the federal proxy rules. See Rules 14a-2 and 14a-3 and the definitions of “solicitat ion” and “proxy.” Please advise why you
believe you are in compliance with the so licitation requirements of the federal
proxy rules, or explain what steps you w ill take to correct your noncompliance.
CirTran Corporation
March 1, 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 responses to our comments and provides any requested information. Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.
Please contact Tom Jones at (202) 551- 3602 or me at (202) 551-3800 with any
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