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SEC Comment Letter for CAREADVANTAGE INC (CIK 0000937252) — Aug 5, 2005

CAREADVANTAGE INC (CIK 0000937252)
Date: Aug. 5, 2005 · CIK: 0000937252 · Accession: 0000000000-05-040557

AI Filing Summary & Sentiment

Referenced dates: July 26, 2005

Date
August 5, 2005
Author
Cicely Luckey
Form
UPLOAD
Company
CAREADVANTAGE INC (CIK 0000937252)

Letter

Mail Stop 4561 VIA U.S. MAIL AND FAX 1-732-362-5005 Mr. Dennis Mouras Chief Financial Officer Careadvantage, Inc. 485-C Route 1 South Iselin, New Jersey 08830

RE: Careadvantage, Inc. Form 10-KSB for the year ended December 31, 2004 Form 10-QSB for the quarter ended March 31, 2005 File no. 0-26168

Dear Mr. Mouras:

We have reviewed your response letter dated July 26, 2005 and have the following additional comments.

In our comments, we ask you to provide us with information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments.

Form 10-K for the fiscal year ended March 31, 2004

1. We have considered your response to comment 3 and request further clarification on how you met the criteria in paragraphs 15 and 16 of SFAS 146 in determining when to recognize the liability associated with your operating lease. Please advise us how you determined the cease-use date if you continued to use a portion of the facilities for your ongoing business operations.

As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response.

If you have any questions, you may contact Kelly McCusker at (202) 551-3433 or me at (202) 551-3413.

Sincerely,
Cicely Luckey
Branch Chief

Show Raw Text
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<TEXT>

      August 5, 2005

Mail Stop 4561

VIA U.S. MAIL AND FAX 1-732-362-5005

Mr. Dennis Mouras
Chief Financial Officer
Careadvantage, Inc.
485-C Route 1 South
Iselin, New Jersey  08830

RE:	Careadvantage, Inc.
Form 10-KSB for the year ended December 31, 2004
Form 10-QSB for the quarter ended March 31, 2005
File no. 0-26168

Dear Mr. Mouras:

      We have reviewed your response letter dated July 26, 2005
and
have the following additional comments.

      In our comments, we ask you to provide us with information
so
we may better understand your disclosure.  Please be as detailed
as
necessary in your explanation.  After reviewing this information,
we
may raise additional comments.

Form 10-K for the fiscal year ended March 31, 2004

1. We have considered your response to comment 3 and request
further
clarification on how you met the criteria in paragraphs 15 and 16
of
SFAS 146 in determining when to recognize the liability associated
with your operating lease.  Please advise us how you determined
the
cease-use date if you continued to use a portion of the facilities
for your ongoing business operations.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.

      If you have any questions, you may contact Kelly McCusker at
(202) 551-3433 or me at (202) 551-3413.

      Sincerely,

							Cicely Luckey
      Branch Chief

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Mr. Dennis Mouras
Careadvantage, Inc.
August 5, 2005
Page 1

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