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SEC Company Response from INFINITY ENERGY RESOURCES, INC (AMNI) (CIK 0000822746) — Nov 14, 2005

INFINITY ENERGY RESOURCES, INC (AMNI) (CIK 0000822746)
Date: Nov. 14, 2005 · CIK: 0000822746 · Accession: 0000950134-05-021568

AI Filing Summary & Sentiment

Referenced dates: November 9, 2005

Date
November 14, 2005
Author
/s/ Timothy A. Ficker
Form
CORRESP
Company
INFINITY ENERGY RESOURCES, INC (AMNI) (CIK 0000822746)

Letter

Securities and Exchange Commission Division of Corporation Finance Attention: Ms. Jill Davis Infinity Energy Resources, Inc. Form 8-K Filed November 7, 2005 File No. 0-17204

Dear Ms. Davis:

On behalf of Infinity Energy Resources, Inc. (the “Company”), set forth below is the response of the Company to the comments received from the Staff of the Securities and Exchange Commission contained in the letter dated November 9, 2005 regarding the above-referenced filing.

Comment 1: Please confirm, if true, that your certifying officers will reconsider the effect on the adequacy of your disclosure controls and procedures as of the end of the period(s) covered by your amended filings for all required periods in light of the financial accounting issue you have identified.

Response 1: We confirm that our certifying officers have reconsidered the effect on the adequacy of our disclosure controls and procedures as of the end of the period(s) covered by our amended filings for all required periods in light of the financial accounting issue we have identified. To that end, we have revised the disclosure in Item 4 of Part 1 of our Quarterly Report on Form 10-Q/A for the quarters ended March 31, 2005 and June 30, 2005, filed today.

Comment 2: We note that you intend to file restated financial statements for the affected periods. Please indicate when you expect to file your restated financial statements. We may have further comment after you file the restated financial statements.

Ms. Jill Davis

Securities and Exchange Commission

November 14, 2005

Page 2

Response 2: We filed Forms 10-Q/A with restated financial statements for the affected periods today, November 14, 2005.

Please call me at (720) 932-6892 if you would like to discuss these matters.

Very truly yours,
/s/ Timothy A. Ficker

Show Raw Text
CORRESP
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November 14, 2005

By
EDGAR, Facsimile (202) 772-9220 and Federal Express

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Jill Davis

    Re:

    Infinity Energy Resources, Inc.

Form 8-K

Filed November 7, 2005

File No. 0-17204

Dear Ms. Davis:

On behalf of Infinity Energy Resources, Inc. (the “Company”), set forth below is the response of
the Company to the comments received from the Staff of the Securities and Exchange Commission
contained in the letter dated November 9, 2005 regarding the above-referenced filing.

Comment 1: Please confirm, if true, that your certifying officers will reconsider the effect on the
adequacy of your disclosure controls and procedures as of the end of the period(s) covered by your
amended filings for all required periods in light of the financial accounting issue you have
identified.

Response 1: We confirm that our certifying officers have reconsidered the effect on the
adequacy of our disclosure controls and procedures as of the end of the period(s) covered by our
amended filings for all required periods in light of the financial accounting issue we have
identified. To that end, we have revised the disclosure in Item 4 of Part 1 of our Quarterly
Report on Form 10-Q/A for the quarters ended March 31, 2005 and June 30, 2005, filed today.

Comment 2: We note that you intend to file restated financial statements for the affected periods.
Please indicate when you expect to file your restated financial statements. We may have further
comment after you file the restated financial statements.

Ms. Jill Davis

Securities and Exchange Commission

November 14, 2005

Page 2

Response 2: We filed Forms 10-Q/A with restated financial statements for the affected
periods today, November 14, 2005.

Please call me at (720) 932-6892 if you would like to discuss these matters.

Very truly yours,

/s/ Timothy A. Ficker

Timothy A. Ficker

Vice President, Chief Financial Officer

    cc:

    James A. Tuell, Infinity Energy Resources, Inc.

Deborah Friedman, Esq.