SEC Comment Letter for PACKETPORT COM (CIK 0000833203) — Dec 27, 2005
PACKETPORT COM (CIK 0000833203)
Date: Dec. 27, 2005 · CIK: 0000833203 · Accession: 0000000000-05-063949
AI Filing Summary & Sentiment
Letter
Mail Stop 4561 December 27, 2005 Mr. Ronald A. Durando President and Chief Executive Officer Packetport.com, Inc. 587 Connecticut Ave. Norwalk, CT 06854-0566
RE: Packetport.com, Inc. Form 8-K filed December 22, 2005 File No. 0-19705
Dear Mr. Durando:
We have reviewed your filing and have the following 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 necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not 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 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 me at the telephone number listed at the end of this letter.
Form 8-K filed December 22, 2005
1. Amend the report to include all of the information required by Item 304 of Regulation S-B. Item 304(a)(1) of Regulation S-B requires a statement whether during the registrant`s two most recent fiscal years and any subsequent interim period through the date of resignation, declination or dismissal there were any disagreements with the former accountant on any matter of accounting principles or practices, financial statement disclosure, or auditing scope or procedure, which disagreement(s), if not resolved to the satisfaction of the former accountant, would have caused it to make reference to the subject matter of the disagreement(s) in connection with its reports. In the event of disagreement(s) and/or reportable event(s), provide the specific disclosures required by Item 304(a)(1)(iv) and (v) of Regulation S- B.
Exhibit 16
2. To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountant stating whether the accountant agrees with the statements made in your revised Form 8-K.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging 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 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 that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
Please provide the supplemental information requested above within five business days from the date of this letter. The supplemental information should be filed as correspondence on EDGAR.
Any questions regarding the above should be directed to me at (202) 551-3432.
Sincerely,
William H. Demarest
Staff Accountant
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Mail Stop 4561
December 27, 2005
Mr. Ronald A. Durando
President and Chief Executive Officer
Packetport.com, Inc.
587 Connecticut Ave.
Norwalk, CT 06854-0566
RE: Packetport.com, Inc.
Form 8-K filed December 22, 2005
File No. 0-19705
Dear Mr. Durando:
We have reviewed your filing and have the following
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 necessary in your
explanation. In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure. After reviewing this information, we may or may not
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 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 me at the telephone
number
listed at the end of this letter.
Form 8-K filed December 22, 2005
1. Amend the report to include all of the information required
by
Item 304 of Regulation S-B. Item 304(a)(1) of Regulation S-B
requires a statement whether during the registrant`s two most
recent fiscal years and any subsequent interim period through
the
date of resignation, declination or dismissal there were any
disagreements with the former accountant on any matter of
accounting principles or practices, financial statement
disclosure,
or auditing scope or procedure, which disagreement(s), if not
resolved to the satisfaction of the former accountant, would
have
caused it to make reference to the subject matter of the
disagreement(s) in connection with its reports. In the event of
disagreement(s) and/or reportable event(s), provide the specific
disclosures required by Item 304(a)(1)(iv) and (v) of Regulation
S-
B.
Exhibit 16
2. To the extent that you make changes to the Form 8-K to comply
with our comments, please obtain and file an updated Exhibit 16
letter from the former accountant stating whether the accountant
agrees with the statements made in your revised Form 8-K.
We urge all persons who are responsible for the accuracy
and
adequacy of the disclosure in the filing reviewed by the staff
to
be certain that they have provided all information investors
require for an informed investment decision. Since the company
and
its management are in possession of all facts relating to a
company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
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 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 that the Division of
Enforcement has access to all information you provide to the
staff
of the Division of Corporation Finance in our review of your
filing
or in response to our comments on your filing.
Please provide the supplemental information requested above
within five business days from the date of this letter. The
supplemental information should be filed as correspondence on
EDGAR.
Any questions regarding the above should be directed to me
at
(202) 551-3432.
Sincerely,
William H. Demarest
Staff Accountant
??
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??
Mr. Ronald A. Durando
Packetport.com, Inc.
December 27, 2005
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