SEC Company Response from SIRICOMM INC (CIK 0000851199) — Nov 1, 2005
SIRICOMM INC (CIK 0000851199)
Date: Nov. 1, 2005 · CIK: 0000851199 · Accession: 0001038838-05-000938
AI Filing Summary & Sentiment
Referenced dates: October 20, 2005
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SOMMER & SCHNEIDER LLP
595 STEWART AVENUE, SUITE 710
GARDEN CITY, NEW YORK 11530
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Herbert H. Sommer Telephone (516) 228-8181
Joel C. Schneider Facsimile (516) 228-8211
November 1, 2005
VIA EDGAR AND FEDERAL EXPRESS
Securities and Exchange Commission
450 5th Street, N.W.
Washington, DC 20549
Attn: Patrick Gilmore, Division of Corporation Finance
Re: SiriCOMM, Inc.
Form 10-K for the Fiscal Year ended September 30, 2004 Filed
January 13, 2005 File No. 0-18399
Ladies and Gentlemen:
We write this letter on behalf of SiriCOMM, Inc. (the "Company") in
response to your Letter of Comment dated October 20, 2005, relating to the
Company's above referenced filing. Please note that we are filing herewith
amendments to the Company's Form 10-KSB for the year ended September 30, 2004
and the Company's Form 10-QSB's for the quarters ended December 31, 2004, March
31, 2005 and June 30, 2005. Each of these amendments has been amended to reflect
the following:
General
1. The Company is, simultaneously herewith, filing an Item 4.02 8-K. The Company
considered filing an Item 4.02 8-K with its amended filings but did not believe
the restatement was material at that time. It has subsequently reconsidered that
position and as a result decided it was necessary to file an Item 4.02 8-K.
2. After further evaluation, the Company has determined that its disclosure
controls and procedures were not effective. We have revised our Controls and
Procedures sections of our 10-KSB for the year ended September 30, 2004 and Form
10-QSB's for the quarters ended December 31, 2004, March 31, 2005 and June 30,
2005 to revise this section in each filing accordingly.
3. See response to comment 2. We have revised this entire section to state that
our controls and procedures are not effective and to explain why they were not
effective.
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Securities and Exchange Commission
November 1, 2005
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4. We have revised this section to expressly identify the material weaknesses in
our internal controls over financial reporting and any significant deficiency
that, when combined with other significant deficiencies is determined to be a
material weakness.
We have carefully reviewed the Staff's comments and have set forth our
responses above. We have incorporated such responses, where applicable, in our
amendments to Form 10-KSB for the year ended September 30, 2004 and Form
10-QSB's for the quarters ended December 31, 2004, March 31, 2005 and June 30,
2005.
I welcome a further discussion on any of our points addressed within
this response letter. I may be reached at (516) 228-8181, ext. 22.
Very truly yours,
/s/ Joel C. Schneider
Joel C. Schneider
JCS/md
cc: Hank Hoffman
J. Richard Iler
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