SEC Comment Letter for INTERNET INFINITY INC (CIK 0001020302) — Oct 28, 2005
INTERNET INFINITY INC (CIK 0001020302)
Date: Oct. 28, 2005 · CIK: 0001020302 · Accession: 0000000000-05-055020
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 October 28, 2005 George Morris President Internet Infinity, Inc. 413 Avenue G. #1 Redondo Beach, CA 90277
Re: Internet Infinity, Inc. Preliminary Information Statement on Schedule 14C Filed October 18, 2005 File No. 0-27633
Dear Mr. Morris:
We have limited our review of your filing to the issues addressed in our 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 information so we may better understand your disclosure. After reviewing this information, we may 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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. 1. We note you propose to amend your Articles of Incorporation to increase your authorized common stock and preferred stock. It also appears you intend to engage in an acquisition and have retained a consultant for this purpose. Please disclose whether you have any current plans, intentions, or arrangements to engage in an acquisition. If not, please revise to clearly disclose you have no plans. 2. In addition, if you do have current plans to engage in an acquisition, please consider the application of Note A to Schedule 14A.
* * * *
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. 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 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 urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. Since the filing persons are in possession of all facts relating to the filing persons` 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 all filing persons acknowledging that:
* the company is responsible for the adequacy and accuracy of the disclosure in the filing;
* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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 advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
Please contact Matthew Benson at (202) 551-3335 or David Mittelman, Legal Branch Chief, at (202) 551-3214 with any questions you may have.
Sincerely,
H. Christopher Owings
Assistant Director
Show Raw Text
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Mail Stop 3561
October 28, 2005
George Morris
President
Internet Infinity, Inc.
413 Avenue G. #1
Redondo Beach, CA 90277
Re: Internet Infinity, Inc.
Preliminary Information Statement on Schedule 14C
Filed October 18, 2005
File No. 0-27633
Dear Mr. Morris:
We have limited our review of your filing to the issues
addressed in our 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 information so we may better understand
your
disclosure. After reviewing this information, we may 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 any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
1. We note you propose to amend your Articles of Incorporation to
increase your authorized common stock and preferred stock. It
also
appears you intend to engage in an acquisition and have retained a
consultant for this purpose. Please disclose whether you have any
current plans, intentions, or arrangements to engage in an
acquisition. If not, please revise to clearly disclose you have
no
plans.
2. In addition, if you do have current plans to engage in an
acquisition, please consider the application of Note A to Schedule
14A.
* * * *
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. 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 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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
filing persons are in possession of all facts relating to the
filing
persons` 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 all filing persons acknowledging
that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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 advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
Please contact Matthew Benson at (202) 551-3335 or David
Mittelman, Legal Branch Chief, at (202) 551-3214 with any
questions
you may have.
Sincerely,
H. Christopher Owings
Assistant Director
cc: Thomas Kenan, Esq.
Fuller, Tubb, Pomeroy & Stokes
Via Fax - (405) 232-8384
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George Morris
Internet Infinity, Inc.
October 28, 2005
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