SEC Comment Letter for HARTCOURT COMPANIES INC (CIK 0000949427) — Jun 13, 2005
HARTCOURT COMPANIES INC (CIK 0000949427)
Date: June 13, 2005 · CIK: 0000949427 · Accession: 0000000000-05-029354
AI Filing Summary & Sentiment
Referenced dates: May 27, 2005
Letter
June 10, 2005 Mail Stop 4561 Ms. Carrie Hartwick Interim Chief Financial Officer Hartcourt Companies, Inc. 3F, 710 Chang Ping Road Shanghai 200040 China
Re: Hartcourt Companies, Inc. Form 10-KSB for the year ended December 31, 2004 Form 10-QSB for the quarter ended March 31, 2005 File No. 1-12671
Dear Ms. Hartwick:
We have reviewed your response letter dated May 27, 2005 and have the following additional comments. As previously stated, these comments require amendment to the referenced filings previously filed with the Commission.
Form 10-KSB for the year ended December 31, 2004
Consolidated Financial Statements
Report of Independent Registered Public Accounting Firm
1. We have read your response to prior comment 1 and await the filing of your Form 10-KSB, amended to include an audit report for the fiscal year. Please tell us when you plan to file this Form 10- KSB amendment. Upon our review of your Form 10-KSB amendment, we may have additional comments.
Form 10-QSB for the quarter ended March 31, 2005
2. Based upon your 2004 and 2003 net sales, it appears that you have exceeded the Small Business Issuer revenue limit at the end of two consecutive years. Refer to Item 10 of Regulation S-B. Considering that you are no longer considered a small business, please confirm to us that you will file Exchange Act reports pursuant to Regulation S-K beginning with the quarterly period ended June 30, 2005 or advise us.
As appropriate, please amend your Form 10-KSB and respond to these comments within 10 business days or tell us when you will provide us with a response. 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 file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Rachel Zablow, Staff Accountant at (202) 551- 3428 or the undersigned at (202) 551-3403 if you have questions.
Sincerely,
Steven Jacobs
Accounting Branch Chief
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
June 10, 2005
Mail Stop 4561
Ms. Carrie Hartwick
Interim Chief Financial Officer
Hartcourt Companies, Inc.
3F, 710 Chang Ping Road
Shanghai 200040
China
Re: Hartcourt Companies, Inc.
Form 10-KSB for the year ended December 31, 2004
Form 10-QSB for the quarter ended March 31, 2005
File No. 1-12671
Dear Ms. Hartwick:
We have reviewed your response letter dated May 27, 2005 and
have the following additional comments. As previously stated,
these
comments require amendment to the referenced filings previously
filed
with the Commission.
Form 10-KSB for the year ended December 31, 2004
Consolidated Financial Statements
Report of Independent Registered Public Accounting Firm
1. We have read your response to prior comment 1 and await the
filing
of your Form 10-KSB, amended to include an audit report for the
2003
fiscal year. Please tell us when you plan to file this Form 10-
KSB
amendment. Upon our review of your Form 10-KSB amendment, we may
have additional comments.
Form 10-QSB for the quarter ended March 31, 2005
2. Based upon your 2004 and 2003 net sales, it appears that you
have
exceeded the Small Business Issuer revenue limit at the end of two
consecutive years. Refer to Item 10 of Regulation S-B.
Considering
that you are no longer considered a small business, please confirm
to
us that you will file Exchange Act reports pursuant to Regulation
S-K
beginning with the quarterly period ended June 30, 2005 or advise
us.
As appropriate, please amend your Form 10-KSB and respond to
these comments within 10 business days or tell us when you will
provide us with a response. 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 file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.
You may contact Rachel Zablow, Staff Accountant at (202)
551-
3428 or the undersigned at (202) 551-3403 if you have questions.
Sincerely,
Steven Jacobs
Accounting Branch Chief
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Hartcourt Companies, Inc.
June 10, 2005
Page 2
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