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SEC Comment Letter for Investview, Inc. (INVU, INVUP) (CIK 0000862651) (INVU) — Jun 9, 2005

Investview, Inc. (INVU, INVUP) (CIK 0000862651)
Date: June 9, 2005 · CIK: 0000862651 · Accession: 0000000000-05-028849

AI Filing Summary & Sentiment

Date
June 9, 2005
Author
Branch Chief
Form
UPLOAD
Company
Investview, Inc. (INVU, INVUP) (CIK 0000862651)

Letter

June 9, 2005 Via facsimile and U.S. Mail Mr. James Anderson President and Director Uintah Mountain Coppery Company 378 North Main, #124 Layton, Utah 84061

Re: Uintah Mountain Copper Company Preliminary Proxy Materials on Schedule 14C Sumbitted supplementally on May 27, 2005 File No. 0-27019

Dear Mr. Anderson:

We have reviewed your submitted supplemental materials 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 comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Reverse Split, page 2

1. Revise your Information Statement to state that, since you are not reversing the shares of shareholders holding less than 100 shares, those shareholders will hold a larger percentage of the outstanding shares after the reverse stock split. Also, disclose in a table or other similar format the number of shares of your common stock that will be: (i) issued and outstanding; (ii) authorized and reserved for issuance; and (iii) authorized but unreserved as a result of the adoption of the reverse stock split.

2. We note your disclosure that the "shareholders have previously authorized the Company to change its name to a name to be determined at a later date by the Board of Directors." Expand your disclosure to identify the date upon which such authorization was received. 3. We call your attention to Rule 10b-17, which you should consult in connection with the process of implementing any reverse stock split. 4. It appears that the reverse stock split would result in an increased number of authorized but unissued shares of your common stock. Do you have any current plans, proposals or arrangements to issue any of the additional shares? For example, are there any proposals or plans to acquire any business or engage in any investment opportunity with the additional shares? If so, please disclose and if not, please state that you have no such plans, proposals or arrangements written or otherwise at this time. In that regard, we note your disclosure on page 4 that you are "currently seeking business opportunities to acquire or merge with." Supplementally, advise as to whether you are currently in negotiations or have signed any letters of intent with other companies. We may have further comment upon reviewing your response.

No Meeting Being Held, page 3

5. State the percentage of outstanding shares required to be voted in favor of the proposal.

6. Identify the shareholder(s) that have consented to vote in favor of the reverse stock split. Also, identify how those shareholders were solicited and the percentage of shares being voted in favor of the proposal.

Closing Comments

As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and 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 contact Melinda Kramer at (202) 942-1938 or me at (202) 942-1837, with other questions. Address all correspondence to mail- stop 04-05.

Sincerely,
Tangela Richter
Branch Chief

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
								June 9, 2005

Via facsimile and U.S. Mail

Mr. James Anderson
President and Director
Uintah Mountain Coppery Company
378 North Main, #124
Layton, Utah  84061

	Re:	Uintah Mountain Copper Company
		Preliminary Proxy Materials on Schedule 14C
      Sumbitted supplementally on May 27, 2005
		File No. 0-27019

Dear Mr. Anderson:

	We have reviewed your submitted supplemental materials 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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Reverse Split, page 2

1. Revise your Information Statement to state that, since you are
not
reversing the shares of shareholders holding less than 100 shares,
those shareholders will hold a larger percentage of the
outstanding
shares after the reverse stock split.  Also, disclose in a table
or
other similar format the number of shares of your common stock
that
will be: (i) issued and outstanding; (ii) authorized and reserved
for
issuance; and (iii) authorized but unreserved as a result of the
adoption of the reverse stock split.

2. We note your disclosure that the "shareholders have previously
authorized the Company to change its name to a name to be
determined
at a later date by the Board of Directors."  Expand your
disclosure
to identify the date upon which such authorization was received.
3. We call your attention to Rule 10b-17, which you should consult
in
connection with the process of implementing any reverse stock
split.
4. It appears that the reverse stock split would result in an
increased number of authorized but unissued shares of your common
stock.  Do you have any current plans, proposals or arrangements
to
issue any of the additional shares?  For example, are there any
proposals or plans to acquire any business or engage in any
investment opportunity with the additional shares?  If so, please
disclose and if not, please state that you have no such plans,
proposals or arrangements written or otherwise at this time.  In
that
regard, we note your disclosure on page 4 that you are "currently
seeking business opportunities to acquire or merge with."
Supplementally, advise as to whether you are currently in
negotiations or have signed any letters of intent with other
companies.  We may have further comment upon reviewing your
response.

No Meeting Being Held, page 3

5. State the percentage of outstanding shares required to be voted
in
favor of the proposal.

6. Identify the shareholder(s) that have consented to vote in
favor
of the reverse stock split.  Also, identify how those shareholders
were solicited and the percentage of shares being voted in favor
of
the proposal.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and 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 contact Melinda Kramer at (202) 942-1938 or me at
(202)
942-1837, with other questions.  Address all correspondence to
mail-
stop 04-05.

								Sincerely,

								Tangela Richter
								Branch Chief

CC:	Nathan Trage, Esq.

      Melinda Kramer

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Mr. James Anderson
Uintah Mountain Copper Company
June 9, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE
Mail Stop 04-05

</TEXT>
</DOCUMENT>