SEC Comment Letter for GLOBAL AXCESS CORP (CIK 0000852570) — Jul 14, 2005
GLOBAL AXCESS CORP (CIK 0000852570)
Date: July 14, 2005 · CIK: 0000852570 · Accession: 0000000000-05-036240
AI Filing Summary & Sentiment
File numbers found in text: 000-17874
Letter
July 14, 2005 By mail and fax to: (305) 356-1611 Mr. David Fann President Global Axcess Corp 224 Ponte Vedra Park Drive Ponte Vedra Beach, FL 32082
Re: Global Axcess Corp. Form 8-K filed June 24, 2005 Form 8-K/A filed June 29, 2005 File No. 000-17874
Dear Mr. Fann,
The Staff has reviewed the above-referenced filings for compliance with the requirements of Form 8-K and has the following comment in that regard:
* Please revise to specifically state whether the former accountant resigned, declined to stand for re-election or was dismissed, as required by Item 304(a)(1)(i) of Regulation S-B. It is not sufficient to state that the company "terminated" the relationship with its former accountant, as that wording is unclear to a reader. Include a letter from the former accountants addressing the revised disclosures in the amendment.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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 file an amendment via EDGAR in response to these comments within 5 business days of the date of this letter, unless specified otherwise, or contact us immediately if you require additional time. Such amendment should be filed under cover of Form 8-K/A and should include the ITEM 4 designation. To expedite the processing of the Form 8-K, please furnish a courtesy copy of the filing to the undersigned.
You may direct any questions regarding these comments to me at (202) 551-3424.
Sincerely,
Lisa Haynes
Staff Accountant
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Mail Stop 4561
July 14, 2005
By mail and fax to: (305) 356-1611
Mr. David Fann
President
Global Axcess Corp
224 Ponte Vedra Park Drive
Ponte Vedra Beach, FL 32082
Re: Global Axcess Corp.
Form 8-K filed June 24, 2005
Form 8-K/A filed June 29, 2005
File No. 000-17874
Dear Mr. Fann,
The Staff has reviewed the above-referenced filings for
compliance with the requirements of Form 8-K and has the following
comment in that regard:
* Please revise to specifically state whether the former
accountant
resigned, declined to stand for re-election or was dismissed, as
required by Item 304(a)(1)(i) of Regulation S-B. It is not
sufficient to state that the company "terminated" the relationship
with its former accountant, as that wording is unclear to a
reader.
Include a letter from the former accountants addressing the
revised
disclosures in the amendment.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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 file an amendment via EDGAR in response to these
comments
within 5 business days of the date of this letter, unless
specified
otherwise, or contact us immediately if you require additional
time.
Such amendment should be filed under cover of Form 8-K/A and
should
include the ITEM 4 designation. To expedite the processing of the
Form 8-K, please furnish a courtesy copy of the filing to the
undersigned.
You may direct any questions regarding these comments to me at
(202)
551-3424.
Sincerely,
Lisa Haynes
Staff Accountant
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David Fann, President
Global Axcess Corp
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