SEC Comment Letter for BioCardia, Inc. (BCDA) (CIK 0000925741) (BCDA) — Jan 18, 2007
BioCardia, Inc. (BCDA) (CIK 0000925741)
Date: Jan. 18, 2007 · CIK: 0000925741 · Accession: 0000000000-07-002662
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-21419
Letter
Mail Stop 4561 January 18, 2007 Roy Israel 990 Stewart Avenue First Floor Garden City, NY 11530
Re: ClickNsettle.com, Inc. Form 10-KSB for Fiscal Year Ended June 30, 2006 Form 10-QSB for Fiscal Qu arter Ended September 30, 2006 File No. 000-21419
Dear Mr. Israel:
We have reviewed your filings and have the following comments. We have limited our review to only your financial stat ements and related disclosures and do not intend to expand our review to other portions of your docum ents. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your expl anation. In some of our comments, we may ask you to provide us in formation so we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional comments.
Please understand that the purpose of our re view 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 on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Item 8 – Changes in and disagreements w ith accountants on accounting and financial disclosure, page 11
Item 8A – Controls a nd Procedures, page 11 1. We noted that you evaluated disclosure c ontrols and procedures within 90 days prior to the filing date for the year ended June 30, 2006 and the period ended September 30, 2006. Advise us on how you comply with the requirements in Item 307 of Regulation S-B to conclude on the effectiveness as of the end of the period covered by the report, or revise accordingly.
* * * *
Roy Israel ClickNsettle.com, Inc. January 18, 2007 Page 2
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Detailed cover letters gr eatly facilitate our review. Please file your cover letter on E DGAR. Please understa nd that we may have additional comments after reviewin g your responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision. Since the company and its management are in possession of all facts re lating 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 filings;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; 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 advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filings or in response to our comments on your filings.
You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the undersigned at (202) 551-3413 if you have questions.
Sincerely,
Cicely LaMothe
Accounting Branch Chief
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Mail Stop 4561 January 18, 2007 Roy Israel 990 Stewart Avenue First Floor Garden City, NY 11530 Re: ClickNsettle.com, Inc. Form 10-KSB for Fiscal Year Ended June 30, 2006 Form 10-QSB for Fiscal Qu arter Ended September 30, 2006 File No. 000-21419 Dear Mr. Israel: We have reviewed your filings and have the following comments. We have limited our review to only your financial stat ements and related disclosures and do not intend to expand our review to other portions of your docum ents. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your expl anation. In some of our comments, we may ask you to provide us in formation so we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional comments. Please understand that the purpose of our re view 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 on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Item 8 – Changes in and disagreements w ith accountants on accounting and financial disclosure, page 11 Item 8A – Controls a nd Procedures, page 11 1. We noted that you evaluated disclosure c ontrols and procedures within 90 days prior to the filing date for the year ended June 30, 2006 and the period ended September 30, 2006. Advise us on how you comply with the requirements in Item 307 of Regulation S-B to conclude on the effectiveness as of the end of the period covered by the report, or revise accordingly. * * * * Roy Israel ClickNsettle.com, Inc. January 18, 2007 Page 2 As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Detailed cover letters gr eatly facilitate our review. Please file your cover letter on E DGAR. Please understa nd that we may have additional comments after reviewin g your responses to our comments. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision. Since the company and its management are in possession of all facts re lating 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 filings; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; 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 advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filings or in response to our comments on your filings. You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the undersigned at (202) 551-3413 if you have questions. Sincerely, Cicely LaMothe Accounting Branch Chief