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SEC Comment Letter for DarkPulse, Inc. (DPLS) (CIK 0000866439) (DPLS) — Nov 22, 2010

DarkPulse, Inc. (DPLS) (CIK 0000866439)
Date: Nov. 22, 2010 · CIK: 0000866439 · Accession: 0000000000-10-069964

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 000-18730

Referenced dates: November 10, 2010, November 19, 2010

Date
December 31, 2009
Author
Not clearly detected
Form
UPLOAD
Company
DarkPulse, Inc. (DPLS) (CIK 0000866439)

Letter

Via fax (801) 847-6422 N o v e m b e r 2 2 , 2 0 1 0 Paul G. Begum Chairman & CEO Klever Marketing, Inc. 2469 E Ft Union Blvd No. 214 Cottonw ood, UT 84121

Re: Klever Marketing, Inc. Form 10-K & Form 10-K/A for the Fi scal Year Ended December 31, 2009 Filed April 13, 2010 and Ap ril 30, 2010, respectively Form 10-Q for the Quarter Ended March 31, 2010 and Form 10-Q & Form 10-Q/A for the Quarter Ende d June 30, 2010 Filed May 24, 2010 , August 13, 2010 and Augu st 17, 2010, respectively File No. 000-18730

Dear Mr. Begum: We have reviewed your letter dated November 19, 2010 in connection with the above- referenced filings and have the following comment. In our comment, we ma y ask you to provide us with information so we may be tter understand your disclosure. Please respond to this letter within ten busin ess days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and ci rcumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Unless otherwise noted, where prior comments are referred to they refer to our letter dated November 10, 2010. Form 10-Q for the Quarter Ended March 31, 2010 a nd Form 10-Q and Form 10-Q/A for the Quarter Ended June 30, 2010 Item 4(T). Controls a nd Procedures, page 13

Management’s Report on Internal Control over Financial Reporting, page 13 1. Notwithstanding your prior response to prior comment 3, we continue to believe that a revision is required to remove the discussion regardi ng the evaluation of your internal controls over financial reporting at March 31, 2010 and June 30, 2010 and to limit your discussion to the

Paul G. Begum Klever Marketing, Inc. November 22, 2010 Page 2 disclosure required by Item 308T(b) for changes in internal control over financial reporting during the quarter. Please re vise your filings accordingly. You may contact Megan Akst, Staff Accountant at (202) 551 -3407 if you have questions regarding comments on the financial statements and related matters. If you need further assistance, you may contact me at (202) 551-3499. Sincerely,

Kathleen Collins Accounting Branch Chief

Show Raw Text
Via fax (801) 847-6422
       N o v e m b e r  2 2 ,  2 0 1 0

Paul G. Begum
Chairman & CEO Klever Marketing, Inc. 2469 E Ft Union Blvd No. 214 Cottonw ood, UT 84121

Re: Klever Marketing, Inc.
 Form 10-K & Form 10-K/A for the Fi scal Year Ended December 31, 2009
 Filed April 13, 2010 and Ap ril 30, 2010, respectively
Form 10-Q for the Quarter Ended March 31, 2010 and Form 10-Q & Form 10-Q/A
for the Quarter Ende d June 30, 2010
 Filed May 24, 2010 , August 13, 2010 and Augu st 17, 2010, respectively
File No. 000-18730

Dear Mr. Begum:
We have reviewed your letter dated November 19, 2010 in connection with the above-
referenced filings and have the following comment.  In our comment, we ma y ask you to provide us
with information so we may be tter understand your disclosure.
 Please respond to this letter within ten busin ess days by amending your filing, by providing the
requested information, or by advising us when you will provide the requested response.  If you do not
believe our comment applies to your facts and ci rcumstances or do not believe an amendment is
appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in response to
this comment, we may have additional comments.  Unless otherwise noted, where prior comments are
referred to they refer to our letter dated November 10, 2010.
 Form 10-Q for the Quarter Ended March 31, 2010 a nd Form 10-Q and Form 10-Q/A for the Quarter
Ended June 30, 2010
 Item 4(T). Controls a nd Procedures, page 13

Management’s Report on Internal Control over Financial Reporting, page 13
 1. Notwithstanding your prior response to prior comment 3, we continue to believe that a revision is required to remove the discussion regardi ng the evaluation of your internal controls over
financial reporting at March 31, 2010 and June 30, 2010 and to limit your discussion to the

 Paul G. Begum Klever Marketing, Inc. November 22, 2010 Page 2
disclosure required by Item 308T(b) for changes in  internal control over  financial reporting
during the quarter.  Please re vise your filings accordingly.
 You may contact Megan Akst, Staff Accountant at (202) 551 -3407 if you have questions
regarding comments on the financial statements and related matters.  If you need further assistance,
you may contact me at (202) 551-3499.
Sincerely,

Kathleen Collins Accounting Branch Chief