SEC Company Response from ARC WIRELESS SOLUTIONS INC (CIK 0000826326) — May 9, 2005
ARC WIRELESS SOLUTIONS INC (CIK 0000826326)
Date: May 9, 2005 · CIK: 0000826326 · Accession: 0001000096-05-000295
AI Filing Summary & Sentiment
File numbers found in text: 000-18122
Referenced dates: April 26, 2005
Letter
Mr. Larry Spirgel Assistant Director United States Securities and Exchange Commission Mail Stop 0407 Washington, D.C. 20549
RE: ARC Wireless Solutions, Inc. Form 10-K for the fiscal year ended December 31, 2004 File no. 000-18122
Dear Mr. Spirgel:
Enclosed please find our responses to your comment letter dated April 26, 2005.
Comment 1 and Comment 2, Form 10-K, Item 9A. Controls and Procedures, as requested, our future filings will provide the disclosure required by Item 307 and Item 308(c) of Regulation S-K.
As of the end of the period covered by our 2004 10-K, the Company evaluated the effectiveness of the design and operation of its disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) promulgated under the Securities Act of 1934, as amended) and its internal controls and procedures for financial reporting. This evaluation was done under the supervision and with the participation of management, including the Chief Executive Officer and Chief Financial Officer. In accord with SEC requirements, the Chief Executive Officer and Chief Financial Officer notes that, since the date of the evaluation to the date of this Annual Report, there have been no significant changes in internal controls or in other factors that could significantly affect internal controls, including any corrective actions with regard to significant deficiencies and material weaknesses. Based upon the Company’s evaluation, the Chief Executive Officer and Chief Financial Officer has concluded that the Company’s disclosure controls are effective to ensure that material information relating to the Company is made known to management, including the Chief Executive Officer and Chief Financial Officer, particularly during the period when the Company’s periodic reports are being prepared, and that the Company’s internal controls are effective to provide reasonable assurance that the Company’s financial statements are fairly presented in conformity with generally accepted accounting principles.
There have been no changes in the Company’s internal control over financial reporting for the fiscal year covered by our 2004 10-K that have materially affected, or are reasonably likely to materially affect the Company’s internal control over financial reporting.
The Company acknowledges that:
o
The Company is responsible for the adequacy and accuracy of the disclosures in the filings;
o
Staff comments or changes to disclosure in response to comments do not foreclose the Commission from taking any action with respect to the filings; and
o
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.
If you should have any additional comments or questions please feel free to contact me at 303-439-8387.
/s/ Monty R. Lamirato
Monty R. Lamirato Chief Financial Officer ARC Wireless Solutions, Inc.
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ARC
WIRELESS SOLUTIONS, INC.
10601
WEST 48TH AVENUE
WHEAT RIDGE,
CO 80033
May 9, 2005
Mr. Larry
Spirgel
Assistant Director
United
States Securities and Exchange Commission
Mail Stop 0407
Washington,
D.C. 20549
RE: ARC
Wireless Solutions, Inc.
Form 10-K for the fiscal year ended December 31, 2004
File no.
000-18122
Dear Mr.
Spirgel:
Enclosed
please find our responses to your comment letter dated April 26, 2005.
Comment
1 and Comment 2, Form 10-K, Item 9A. Controls and Procedures, as requested, our
future filings will provide the disclosure required by Item 307 and Item 308(c)
of Regulation S-K.
As of
the end of the period covered by our 2004 10-K, the Company evaluated the
effectiveness of the design and operation of its disclosure controls and
procedures (as defined in Rules 13a-15(e) and 15d-15(e) promulgated under the
Securities Act of 1934, as amended) and its internal controls and procedures for
financial reporting. This evaluation was done under the supervision and
with the participation of management, including the Chief Executive Officer and
Chief Financial Officer. In accord with SEC requirements, the Chief
Executive Officer and Chief Financial Officer notes that, since the date of the
evaluation to the date of this Annual Report, there have been no significant
changes in internal controls or in other factors that could significantly affect
internal controls, including any corrective actions with regard to significant
deficiencies and material weaknesses. Based upon the Company’s
evaluation, the Chief Executive Officer and Chief Financial Officer has
concluded that the Company’s disclosure controls are effective to ensure
that material information relating to the Company is made known to management,
including the Chief Executive Officer and Chief Financial Officer, particularly
during the period when the Company’s periodic reports are being prepared,
and that the Company’s internal controls are effective to provide
reasonable assurance that the Company’s financial statements are fairly
presented in conformity with generally accepted accounting principles.
There
have been no changes in the Company’s internal control over financial
reporting for the fiscal year covered by our 2004 10-K that have materially
affected, or are reasonably likely to materially affect the Company’s
internal control over financial reporting.
The
Company acknowledges that:
o
The Company is responsible for the adequacy and accuracy of the disclosures in the filings;
o
Staff comments or changes to disclosure in response to comments do not foreclose
the Commission from taking any action with respect to the filings; and
o
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.
If you
should have any additional comments or questions please feel free to contact me
at 303-439-8387.
/s/ Monty R.
Lamirato
Monty R.
Lamirato
Chief Financial Officer
ARC Wireless Solutions, Inc.