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
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File numbers found in text: 000-29142
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CORRESP 1 filename1.htm 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