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SEC Comment Letter for AVAX TECHNOLOGIES INC (CIK 0001015441) — Nov 23, 2004

AVAX TECHNOLOGIES INC (CIK 0001015441)
Date: Nov. 23, 2004 · CIK: 0001015441 · Accession: 0000000000-04-037694

AI Filing Summary & Sentiment

File numbers found in text: 000-29222

Date
November 23, 2004
Author
Oscar M. Young, Jr.
Form
UPLOAD
Company
AVAX TECHNOLOGIES INC (CIK 0001015441)

Letter

Via Facsimile and U.S. Mail Mail Stop 03-09 November 23, 2004 Mr. Richard P. Rainey President Avax Technologies, Inc. 2000 Hamilton Street, Suite 204 Philadelphia, PA 19130

Re: Avax Technologies, Inc. Form 8-K filed September 28, 2004 Form 8-K/A filed November 18, 2004 File No. 000-29222

Dear Mr. Rainey:

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.

Please understand that the purpose of our review 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.

1. As we had requested on September 28, 2004, please revise you filing to specifically state whether the resignation of the former accountant was recommended or approved by the audit or similar committee of the board of directors or the board of directors, if you have no such committee, as required by Item 304(a)(1)(iii) of Regulation S-B.

Please file your supplemental response and amendment via EDGAR in response to these comments within 5 business days of the date when the former accountant ultimately resigns. Please note that if you require longer than 5 business days to respond, you should contact the staff immediately to request additional time. Direct any questions regarding the above to me at (202) 942-2902.

Sincerely,
Oscar M. Young, Jr.
Senior Accountant
Mr. Richard P. Rainey
Avax Technologies, Inc.
Page 1

Show Raw Text
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<DESCRIPTION>ACCTG CMNTS DATED 11/23/04 - ITEM 4.01 8-K AMENDED 11/18/04 (FIRST FILED 09/28/04) - YOUNG
<TEXT>

Via Facsimile and U.S. Mail
Mail Stop 03-09

November 23, 2004

Mr. Richard P. Rainey
President
Avax Technologies, Inc.
2000 Hamilton Street, Suite 204
Philadelphia, PA 19130

Re:	Avax Technologies, Inc.
Form 8-K filed September 28, 2004
Form 8-K/A filed November 18, 2004
File No. 000-29222

Dear Mr. Rainey:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation as
to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review 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.

1. As we had requested on September 28, 2004, please revise you filing
to specifically state whether the resignation of the former accountant
was recommended or approved by the audit or similar committee of the
board of directors or the board of directors, if you have no such
committee, as required by Item 304(a)(1)(iii) of Regulation S-B.

Please file your supplemental response and amendment via EDGAR in
response to these comments within 5 business days of the date when the
former accountant ultimately resigns.  Please note that if you require
longer than 5 business days to respond, you should contact the staff
immediately to request additional time.  Direct any questions
regarding the above to me at (202) 942-2902.

							Sincerely,

							Oscar M. Young, Jr.
							Senior Accountant
Mr. Richard P. Rainey
Avax Technologies, Inc.
Page 1

</TEXT>
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