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SEC Company Response from CAMINOSOFT CORP (CIK 0000907686) — Jun 3, 2005

CAMINOSOFT CORP (CIK 0000907686)
Date: June 3, 2005 · CIK: 0000907686 · Accession: 0001144204-05-018031

AI Filing Summary & Sentiment

Date
June 2, 2005
Author
Stephen W. Crosson
Form
CORRESP
Company
CAMINOSOFT CORP (CIK 0000907686)

Letter

United States Securities and Exchange Commission CaminoSoft Corp. File no. 033-064534-LA Form 10-KSB: For the Year Ended September 30, 2004 Form 10-QSB: For the Quarterly Period Ended December 31, 2004 Form 10-QSB: For the Quarterly Period Ended March 31, 2005

Dear Mr. Wilson:

On behalf of CaminoSoft Corp. (“CaminoSoft” or the “Company”), we hereby submit responses to the comments set forth in the letter from the Securities and Exchange Commission (the “Commission”) dated May 17, 2005.

Annual Report on Form 10-KSB for the Year Ended September 30, 2004

Note 4 - Notes Payable, page F-13

Prior Comment no. 5

1.

We note your discussion regarding the qualitative impact of the amounts you plan to reclassify from deferred financing costs to debt discount. Based on the information provided in your response the misclassification of debt discount results in an overstatement of your assets by approximately 20% and 10% as of September 30, 2004 and 2003, respectively, which appears to be quantitatively material to your financial statements. Restate your annual and interim financial statements, as necessary, to properly classify the discount on your debt, or tell us why the amounts that should be reclassified are not quantitatively material.

Company Response:

In response to your comment we are concurrently filing an amended 10-KSB/A for the fiscal year ended September 30, 2004 covering fiscal years ended September 30, 2004 and 2003, and the relevant interim periods (see footnote 9), together with an amended 10-QSB/A for the quarterly period ended December 31, 2004, which reflect the reclassification of the debt discount.

All questions and comments regarding the foregoing can be addressed to David Ficksman on (310) 789-1290 or the undersigned on (805) 370-3100.

Kind regards,

Stephen W. Crosson Chief Financial Officer CaminoSoft Corp.

cc: David Ficksman

Michael Skelton

Martin Casaus

Show Raw Text
CORRESP
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filename1.htm

    June 2, 2005

      CaminoSoft
      Corp

      600
      Hampshire Road, #105

      Westlake
      Village, CA 91361

      Tel
      (805) 370-3100

      Fax
      (805) 370-3200

      www.caminosoft.com

Craig
Wilson

Senior
Assistant Chief Accountant

United
States Securities and Exchange Commission

450 Fifth
Street, N.W.

Washington,
D.C. 20549

      Re:

    CaminoSoft Corp. File no.
    033-064534-LA

      Form
      10-KSB: For the Year Ended September 30, 2004

    Form 10-QSB: For the Quarterly Period Ended
      December 31, 2004

    Form 10-QSB: For the Quarterly Period Ended
      March 31, 2005

Dear Mr.
Wilson:

On behalf
of CaminoSoft Corp. (“CaminoSoft” or the “Company”), we hereby submit responses
to the comments set forth in the letter from the Securities and Exchange
Commission (the “Commission”) dated May 17, 2005.

Annual
Report on Form 10-KSB for the Year Ended September 30, 2004

Note 4
- Notes Payable, page F-13

Prior
Comment no. 5

    1.

      We
      note your discussion regarding the qualitative impact of the amounts you
      plan to reclassify from deferred financing costs to debt discount. Based
      on the information provided in your response the misclassification of debt
      discount results in an overstatement of your assets by approximately 20%
      and 10% as of September 30, 2004 and 2003, respectively, which appears to
      be quantitatively material to your financial statements. Restate your
      annual and interim financial statements, as necessary, to properly
      classify the discount on your debt, or tell us why the amounts that should
      be reclassified are not quantitatively material.

Company
Response:

In
response to your comment we are concurrently filing an amended 10-KSB/A for the
fiscal year ended September 30, 2004 covering fiscal years ended September 30,
2004 and 2003, and the relevant interim periods (see footnote 9), together with
an amended 10-QSB/A for the quarterly period ended December 31, 2004, which
reflect the reclassification of the debt discount.

All
questions and comments regarding the foregoing can be addressed to David
Ficksman on (310) 789-1290 or the undersigned on (805) 370-3100.

    Kind
      regards,

    Stephen W. Crosson
Chief Financial
      Officer
CaminoSoft Corp.

cc: David
Ficksman

Michael
Skelton

Martin
Casaus