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SEC Company Response from API ELECTRONICS GROUP INC (CIK 0001022282) — Nov 18, 2005

API ELECTRONICS GROUP INC (CIK 0001022282)
Date: Nov. 18, 2005 · CIK: 0001022282 · Accession: 0001193125-05-229205

AI Filing Summary & Sentiment

File numbers found in text: 000-29142

Date
November 18, 2005
Author
Not clearly detected
Form
CORRESP
Company
API ELECTRONICS GROUP INC (CIK 0001022282)

Letter

Securities and Exchange Commission Washington, D.C. 20549 Re: API Electronics Group Corp. Form 20-F for Fiscal Year Ended May 31, 2004 File No. 000-29142

Dear Ms. Akst:

In response to your comment letter to API Electronics Group Corp. (the “Company”) dated September 22, 2005, the Company acknowledges the following:

•

The Company is responsible for the adequacy and accuracy of the disclosure in its Form 20-F and all amendments thereto;

•

Staff comments or changes to disclosure in response to staff comment 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.

Very truly yours,
API ELECTRONICS GROUP CORP.

Show Raw Text
CORRESP
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SEC Letter

 API ELECTRONICS GROUP CORP.

 505 University Avenue

 Suite 1400

 Toronto, Ontario M5G 1X3

 TELEPHONE (416) 563-6543

 November 18, 2005

 Megan Akst

 Staff Accountant

 Securities and Exchange Commission

Mail
Stop 4-06

 Washington, D.C. 20549

Re:
API Electronics Group Corp.

Form 20-F for Fiscal Year Ended May 31, 2004

File No. 000-29142

 Dear Ms. Akst:

 In response to your comment letter to API Electronics Group Corp. (the “Company”) dated September 22, 2005, the Company acknowledges the following:

•

The Company is responsible for the adequacy and accuracy of the disclosure in its Form 20-F and all amendments thereto;

•

Staff comments or changes to disclosure in response to staff comment 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.

 Very truly yours,

 API ELECTRONICS GROUP CORP.

 /s/ Phillip DeZwirek,

 Phillip DeZwirek,

 Chief Executive Officer