SEC Company Response from CAMINOSOFT CORP (CIK 0000907686) — Sep 19, 2005
CAMINOSOFT CORP (CIK 0000907686)
Date: Sept. 19, 2005 · CIK: 0000907686 · Accession: 0001144204-05-029170
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CaminoSoft Corp
600 Hampshire Road, #105
Westlake Village, CA 91361
Tel (805) 370-3100
September 19, 2005
Fax (805) 370-3200
www.caminosoft.com
Mr.
Mark
P. Shuman
Branch
Chief - Legal
United
States Securities and Exchange Commission
Division
of Corporate Finance, Room 4561
Washington,
D.C. 20549
Re: CaminoSoft
Corp. File no. 033-064535-LA
Form
10-KSB for the year ended September 30, 2004
Form
10-QSB for the quarter ended December 31, 2004
Form
10-QSB for the quarter ended March 31, 2005
Form
10-QSB for the quarter ended June 30, 2005
Dear
Mr.
Shuman:
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 September 12, 2005.
Form
10-KSB for the year ended September 30, 2004
Item
8A. Controls and Procedures
1.
We
note your disclosure the “[t]here were no changes in the [your] internal
controls or in other factors that could have significantly affected
those
controls.” Please note that Item 308 of Regulation S-B requires the
disclosure of any changes in your internal controls that occurred
during
your last fiscal quarter that has “materially affected, or is reasonably
likely to materially affect,” your internal controls. In light of the
foregoing, please advise us with respect to changes in your internal
controls for the quarters ended September 30, 2004, December 31,
2004,
March 31, 2005 and June 30, 2005. Please also confirm to us that
you will
consider this comment in preparing future periodic
reports.
Company
Response:
In
response to your comment the Company has amended Item 8A and Item 3, Internal
controls and procedures with a filing of 10-KSB/A (Amendment 2) for the year
ended September 30, 2004 and 10-QSB/A (Amendment 2) for the quarter ended
December 31, 2004 respectively. We indicated in our revised controls and
procedures that they were not effective but have since been remediated. The
Company established additional policies and procedures for review of balance
sheet transactions, specifically transactions relating to debt and equity.
Any
transaction relating to debt and equity including any related expense will
have
a second level of review and consideration to ensure the treatment conforms
with
GAAP.
The
Item
307, Internal controls and procedures was revised to include disclosure of
the
material weakness and remediation of the weakness in Item 8A for the amended
10-KSB and Item 3 for the amended 10-QSB. In addition the Company filed 8-K,
Item 402, non reliance on previously filed financial information.
After
the
filing of the amended financial statements 10-KSB/A (Amendment 2) for the
year
ended September 30, 2004, 10-QSB/A (Amendment 2) for the quarter ended December
31, 2004 and 8-K, Item 402 the company had no changes to internal controls
for
the quarter ended March 31, 2005 and for the quarter ended June 30,
2005.
The
Company confirms it will consider the above referenced comment in preparation
of
all future periodic reports.
We
hereby
confirm the following:
·
should
the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission
from
taking any action with respect to the
filing;
·
the
action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve
the company
from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and
·
the
company may not assert the staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United
States.
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,
/s/
Stephen W. Crosson
Stephen W. Crosson
Chief
Financial Officer
CaminoSoft
Corp.