SEC Comment Letter for DSG INTERNATIONAL LTD (CIK 0000883230) — Nov 4, 2005
DSG INTERNATIONAL LTD (CIK 0000883230)
Date: Nov. 4, 2005 · CIK: 0000883230 · Accession: 0000000000-05-056228
AI Filing Summary & Sentiment
Letter
November 3, 2005 VIA MAIL AND FACSIMILE Mr. Peter Chang, Chief Financial Officer DSG International Limited 17/F Watson Centre 16-22 Kung Yip Street Kwai Chung, N T Hong Kong
Re: DSG International Limited Form 20-F/A for Fiscal Year Ended December 31, 2004 Filed October 25, 2005 File No. 0- 19804
Dear Mr. Chang:
We have considered your amendment filed October 25, 2005 in response to our comments and have the following additional comments. Where indicated, we think you should revise your document in future filings in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a future revision is unnecessary. Please be as detailed as necessary in your explanation.
Form 20-F/A for the Fiscal Year Ended December 31, 2004
Item 15 - Controls and Procedures
1. Please incorporate the following additional changes into your disclosure:
a) To the extent that you chose to include the definition of disclosure controls and procedures in your discussion of your assessment required by Item 15(a) of Form 20-F, please include the entire definition. In this regard, you have omitted the second sentence of the definition as set forth at Exchange Act Rules 13a-15(e) and 15d-15(e).
b) If you are not reporting on your system of internal controls over financial reporting, please exclude the elements of that definition from your definition of disclosure controls and procedures. See Exchange Act Rules 13a-15(f) and 15d-15(f).
Exhibits 12.1 and 12.2
2. Do not include the principal officer`s title in the opening line of the certification. Rather it should be relocated under his signature.
Closing Comments
As appropriate, please comply with these comments in future filings.
You may contact Gabrielle Malits, Staff Accountant, at (202) 551- 3702 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3683 with any other questions.
Sincerely,
Jill Davis
Branch Chief
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<TEXT>
November 3, 2005
VIA MAIL AND FACSIMILE
Mr. Peter Chang, Chief Financial Officer
DSG International Limited
17/F Watson Centre
16-22 Kung Yip Street
Kwai Chung, N T
Hong Kong
Re: DSG International Limited
Form 20-F/A for Fiscal Year Ended December 31, 2004
Filed October 25, 2005
File No. 0- 19804
Dear Mr. Chang:
We have considered your amendment filed October 25, 2005 in
response
to our comments and have the following additional comments. Where
indicated, we think you should revise your document in future
filings in
response to these comments. If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a future
revision is
unnecessary. Please be as detailed as necessary in your
explanation.
Form 20-F/A for the Fiscal Year Ended December 31, 2004
Item 15 - Controls and Procedures
1. Please incorporate the following additional changes into your
disclosure:
a) To the extent that you chose to include the definition of
disclosure
controls and procedures in your discussion of your assessment
required by
Item 15(a) of Form 20-F, please include the entire definition. In
this
regard, you have omitted the second sentence of the definition as
set
forth at Exchange Act Rules 13a-15(e) and 15d-15(e).
b) If you are not reporting on your system of internal controls
over
financial reporting, please exclude the elements of that
definition from
your definition of disclosure controls and procedures. See
Exchange Act
Rules 13a-15(f) and 15d-15(f).
Exhibits 12.1 and 12.2
2. Do not include the principal officer`s title in the opening
line of the
certification. Rather it should be relocated under his signature.
Closing Comments
As appropriate, please comply with these comments in future
filings.
You may contact Gabrielle Malits, Staff Accountant, at (202)
551-
3702 if you have questions regarding comments on the financial
statements
and related matters. Please contact me at (202) 551-3683 with any
other
questions.
Sincerely,
Jill Davis
Branch Chief
cc: Robert Sullivan
Pillsbury Winthrop Shaw Pittman
Facsimile 415-983-1200
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Mr. Patrick Chang
DSG International Limited
November 3, 2005
page 1
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