SEC Comment Letter for LIFE MEDICAL SCIENCES INC (CIK 0000889428) — Apr 19, 2005
LIFE MEDICAL SCIENCES INC (CIK 0000889428)
Date: April 19, 2005 · CIK: 0000889428 · Accession: 0000000000-05-019087
AI Filing Summary & Sentiment
File numbers found in text: 000-20580
Letter
April 19, 2005 Mail Stop 0306 Mr. Robert P. Hickey President, CEO and CFO Life Medical Sciences, Inc. P.O. Box 219 Little Silver, NJ 07739
RE: Life Medical Sciences, Inc. Form 10-KSB for the Fiscal Year Ended December 31, 2004 File No. 000-20580
Dear Mr. Hickey:
We have reviewed your filing 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 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 10-KSB for the Fiscal Year Ended December 31, 2004
Exhibit 31.1
1. We have reviewed your response to comment 7. Your proposed changes to the Section 302 certification include a 6th paragraph which is not in compliance with the text of the certification as set forth in Item 601(b)(31) of Regulation S-B. The required certification must be in the exact form as prescribed. Please revise your proposed changes accordingly.
Response Letter Filed April 15, 2005
2. We note that you did not provide the three acknowledgements in the form previously requested. Accordingly, as indicated below, please provide all three acknowledgements in your response letter.
* * * *
As appropriate, please amend your December 31, 2004 Form 10- KSB 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 supplemental 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 reviewed by the staff to be certain that they have provided all information investors require for an informed 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.
You may contact Tom Dyer, Staff Accountant, at (202) 824- or me at (202) 942-2813 if you have any questions. In this regard, do not hesitate to contact Martin James, the Senior Assistant Chief Accountant, at (202) 942-1984.
Sincerely,
Daniel Gordon
Branch Chief
Show Raw Text
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April 19, 2005
Mail Stop 0306
Mr. Robert P. Hickey
President, CEO and CFO
Life Medical Sciences, Inc.
P.O. Box 219
Little Silver, NJ 07739
RE: Life Medical Sciences, Inc.
Form 10-KSB for the Fiscal Year Ended December 31, 2004
File No. 000-20580
Dear Mr. Hickey:
We have reviewed your filing 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 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 10-KSB for the Fiscal Year Ended December 31, 2004
Exhibit 31.1
1. We have reviewed your response to comment 7. Your proposed
changes to the Section 302 certification include a 6th paragraph
which is not in compliance with the text of the certification as
set
forth in Item 601(b)(31) of Regulation S-B. The required
certification must be in the exact form as prescribed. Please
revise
your proposed changes accordingly.
Response Letter Filed April 15, 2005
2. We note that you did not provide the three acknowledgements in
the
form previously requested. Accordingly, as indicated below, please
provide all three acknowledgements in your response letter.
* * * *
As appropriate, please amend your December 31, 2004 Form 10-
KSB
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 supplemental
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 reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.
You may contact Tom Dyer, Staff Accountant, at (202) 824-
5564
or me at (202) 942-2813 if you have any questions. In this
regard,
do not hesitate to contact Martin James, the Senior Assistant
Chief
Accountant, at (202) 942-1984.
Sincerely,
Daniel Gordon
Branch Chief
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Mr. Robert P. Hickey
Life Medical Sciences, Inc.
April 19, 2005
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