SEC Comment Letter for AMERICAN TONERSERV CORP. (CIK 0001009479) — Aug 10, 2005
AMERICAN TONERSERV CORP. (CIK 0001009479)
Date: Aug. 10, 2005 · CIK: 0001009479 · Accession: 0000000000-05-041197
AI Filing Summary & Sentiment
File numbers found in text: 333-120688
Letter
MAIL STOP 3561 August 5, 2005 Mr. Bryan Klinger, President American TonerServ Corp. 475 Aviation Boulevard Suite 100 Santa Rosa, California 95043
Re: American TonerServ Corp. Amendment No. 3 Registration Statement on Form SB-2 Filed July 18, 2005 File No. 333-120688
Dear Mr. Klinger:
We have reviewed your amended filing and have the following comments. Where indicated, we think you should revise your document in response to these comments.
Management`s Discussion and Analysis, page 9
Overview 1. We note that as of December 31, 2004, you are the primary obligor with 41 companies and have $303,000 of contracts in force. Please update this information to the latest practicable date.
Results of Operations: Comparison of Years Ended December 31 2. In prior comment 12 dated July 8, 2005, we asked that you explain why toner revenue is down. The revised disclosure suggests the reason is because of sales staff reductions and turnover. Please elaborate on these reductions, the reasons for them and how you plan to address the reductions. If these reductions, or the reasons behind them, represent a material risk, consider addressing in a risk factor. Provide similar disclosure under Comparison of Three Months Ended March 31.
Liquidity and Capital Resources 3. Please provide the basis for the following statement: "The base of service providers for our primary market of printers is still large and we believe that we can increase this service base when we execute our business strategy." 4. Please provide your available cash balance as of the latest practicable date.
Certain Transactions, page 28
5. We are unable to locate on Edgar the supplemental legal analysis requested in prior comment 24 dated July 8, 2005. Please file it on Edgar.
Closing Comments
As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. 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 understand that we may have additional comments after reviewing your amendment and responses to our comments.
We direct your attention to Rules 460 and 461 regarding requesting acceleration of a registration statement. Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration. Please provide this request at least two business days in advance of the requested effective date.
Any questions regarding the financial statements may be directed to Angela Halac at (202) 551-3398. Questions on other disclosure issues may be directed to William Bennett at (202) 551- 3389.
Sincerely,
John Reynolds
Assistant Director
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<DOCUMENT>
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<FILENAME>filename1.txt
<TEXT>
MAIL STOP 3561
August 5, 2005
Mr. Bryan Klinger, President
American TonerServ Corp.
475 Aviation Boulevard
Suite 100
Santa Rosa, California 95043
Re: American TonerServ Corp.
Amendment No. 3 Registration Statement on Form SB-2
Filed July 18, 2005
File No. 333-120688
Dear Mr. Klinger:
We have reviewed your amended filing and have the following
comments. Where indicated, we think you should revise your
document
in response to these comments.
Management`s Discussion and Analysis, page 9
Overview
1. We note that as of December 31, 2004, you are the primary
obligor
with 41 companies and have $303,000 of contracts in force. Please
update this information to the latest practicable date.
Results of Operations: Comparison of Years Ended December 31
2. In prior comment 12 dated July 8, 2005, we asked that you
explain
why toner revenue is down. The revised disclosure suggests the
reason is because of sales staff reductions and turnover. Please
elaborate on these reductions, the reasons for them and how you
plan
to address the reductions. If these reductions, or the reasons
behind them, represent a material risk, consider addressing in a
risk
factor. Provide similar disclosure under Comparison of Three
Months
Ended March 31.
Liquidity and Capital Resources
3. Please provide the basis for the following statement: "The
base
of service providers for our primary market of printers is still
large and we believe that we can increase this service base when
we
execute our business strategy."
4. Please provide your available cash balance as of the latest
practicable date.
Certain Transactions, page 28
5. We are unable to locate on Edgar the supplemental legal
analysis
requested in prior comment 24 dated July 8, 2005. Please file it
on
Edgar.
Closing Comments
As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with
marked
copies of the amendment to expedite our review. 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
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.
We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement. Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration. Please provide this
request at least two business days in advance of the requested
effective date.
Any questions regarding the financial statements may be
directed to Angela Halac at (202) 551-3398. Questions on other
disclosure issues may be directed to William Bennett at (202) 551-
3389.
Sincerely,
John Reynolds
Assistant Director
cc: James P. Beck, Esq.
Fax: (303) 893-2882
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Mr. Bryan Klinger, President
American TonerServ Corp.
August 5, 2005
P. 1
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