SEC Comment Letter for GUARDIAN TECHNOLOGIES INTERNATIONAL INC (CIK 0000873198) — Jul 25, 2005
GUARDIAN TECHNOLOGIES INTERNATIONAL INC (CIK 0000873198)
Date: July 25, 2005 · CIK: 0000873198 · Accession: 0000000000-05-038038
AI Filing Summary & Sentiment
File numbers found in text: 000-28238
Letter
Room 4561 July 25, 2005 Michael W. Trudnak Chief Executive Officer Guardian Technologies International, Inc. 516 Herndon Parkway Suite A Herndon, Virginia 20170 703-464-5495
Re: Guardian Technologies International, Inc. Item 4.01 Form 8-K Filed July 20, 2005 File No. 000-28238
Dear Mr. Trudnak:
We have reviewed the above referenced filing and have the following comment. Please note that we have limited our review to the matters addressed in the comment below. We may ask you to provide us with supplemental information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. After reviewing this information, we may 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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 8-K filed July 20, 2005 1. We note your disclosure that during the two most recent fiscal years ended December 31, 2003 and 2004, the Company did not consult with Goodman & Company regarding any of the matters or events set forth in Item 304(a)(2)(i) and (ii) of Regulation S-K. Revise your disclosure to reference Regulation S-B rather than Regulation S-K. Also, revise your disclosure to indicate whether the Company consulted with Goodman & Company during the subsequent interim period regarding any of the matters or events set forth in Item 304(a)(2)(i) and (ii) of Regulation S-B.
*******
As appropriate, please amend your filing and respond to these comments within five business days or tell us when you will provide us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. You may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter with any 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 any amendment and your 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.
If you have any questions, please call Morgan Youngwood at (202) 551-3479, Melissa Walsh at (202) 551-3224 or Stephen Krikorian at (202) 551-3730.
Sincerely,
Stephen Kirkorian
Accounting Branch Chief
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Room 4561
July 25, 2005
Michael W. Trudnak
Chief Executive Officer
Guardian Technologies International, Inc.
516 Herndon Parkway
Suite A
Herndon, Virginia 20170
703-464-5495
Re: Guardian Technologies International, Inc.
Item 4.01 Form 8-K
Filed July 20, 2005
File No. 000-28238
Dear Mr. Trudnak:
We have reviewed the above referenced filing and have the
following comment. Please note that we have limited our review to
the matters addressed in the comment below. We may ask you to
provide us with supplemental information so we may better
understand
your disclosure. Please be as detailed as necessary in your
explanation. After reviewing this information, we may 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 any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 8-K filed July 20, 2005
1. We note your disclosure that during the two most recent fiscal
years ended December 31, 2003 and 2004, the Company did not
consult
with Goodman & Company regarding any of the matters or events set
forth in Item 304(a)(2)(i) and (ii) of Regulation S-K. Revise
your
disclosure to reference Regulation S-B rather than Regulation S-K.
Also, revise your disclosure to indicate whether the Company
consulted with Goodman & Company during the subsequent interim
period
regarding any of the matters or events set forth in Item
304(a)(2)(i)
and (ii) of Regulation S-B.
*******
As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
provide
us with a response. Please submit all correspondence and
supplemental materials on EDGAR as required by Rule 101 of
Regulation
S-T. You may wish to provide us with marked copies of any
amendment
to expedite our review. Please furnish a cover letter with any
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 any amendment and your 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.
If you have any questions, please call Morgan Youngwood at
(202)
551-3479, Melissa Walsh at (202) 551-3224 or Stephen Krikorian at
(202) 551-3730.
Sincerely,
Stephen Kirkorian
Accounting Branch Chief
??
??
??
??
Michael W. Trudnak
Guardian Technologies International, Inc.
July 25, 2005
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