SEC Comment Letter for NextPlat Corp (NXPL) (CIK 0001058307) (NXPL) — Aug 14, 2006
NextPlat Corp (NXPL) (CIK 0001058307)
Date: Aug. 14, 2006 · CIK: 0001058307 · Accession: 0000000000-06-038541
AI Filing Summary & Sentiment
Reasoning
Letter
October 7, 2005 Mail Stop 4561 Benjamin C. Croxton Chief Executive Officer Advanced 3-D Ultrasound Services, Inc. 3900 31st Street North St. Petersburg, Florida 33714
Re: Advanced 3-D Ultrasound Services, Inc. Preliminary Proxy Materials on Schedule 14A Registration No. 0-25097 Filed on September 27, 2005
Dear Mr. Croxton:
This is to advise you that we have lim ited our review of the Preliminary Proxy Materials on Schedule 14A noted above and have the following comments:
1. Please revise to include disclosure with respect to audit fees as required by Item 9(e) of Schedule 14A. 2. Please revise both your Ownership of Securities Table and your Summary Compensation Table for clarity. We note, for example, that with respect to the Security Ownership Table the percentage of securities owned by all officers and directors as a group appears to exceed 54.38%. Likewise, with respect to the Summary Compensation Table, clarificati on is required to ad dress why there are two chief executive officers, presidents, and secretary-treasurers included. Please refer to Items 402 and 403 of Regulation S-B.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing(s) to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company’ s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Additionally, the registrant should provide written acknowle dgement of the following: • The adequacy and accuracy of the disclosu re in the filing is the responsibility of the registrant.
Advanced 3-D Ultrasound Services, Inc. Page 2
• The registrant acknowledges that staff comment or changes in response to staff comment in the proposed disclosu re in the preliminary proxy materials do not foreclose the Commission from taking any action with respect to the filing. • The registrant also represents that st aff comment may not be asserted 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 advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Di vision of Corporation Finance in connection with our review of your filing or in response to our comments on your filing.
All persons who are by statute responsible for the adequacy and accuracy of the information statement are urged to be certain that all information required pursuant to the Securities Exchange Act of 1934 has b een included.
If you have any questions, please call Pa ul Fischer at (202) 551-3415 or the undersigned at (202) 551-3694.
Sincerely,
Owen Pinkerton
Senior Counsel
Show Raw Text
October 7, 2005
Mail Stop 4561
Benjamin C. Croxton
Chief Executive Officer
Advanced 3-D Ultrasound Services, Inc.
3900 31st Street North
St. Petersburg, Florida 33714
Re: Advanced 3-D Ultrasound Services, Inc.
Preliminary Proxy Materials on Schedule 14A
Registration No. 0-25097
Filed on September 27, 2005
Dear Mr. Croxton:
This is to advise you that we have lim ited our review of the Preliminary Proxy
Materials on Schedule 14A noted above and have the following comments:
1. Please revise to include disclosure with respect to audit fees as required by Item
9(e) of Schedule 14A.
2. Please revise both your Ownership of Securities Table and your Summary
Compensation Table for clarity. We note, for example, that with respect to the
Security Ownership Table the percentage of securities owned by all officers and
directors as a group appears to exceed 54.38%. Likewise, with respect to the
Summary Compensation Table, clarificati on is required to ad dress why there are
two chief executive officers, presidents, and secretary-treasurers included. Please
refer to Items 402 and 403 of Regulation S-B.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing(s) to be certain that they have provided all information investors
require for an informed decision. Since the company and its management are in possession of all facts relating to a company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made. Additionally, the registrant
should provide written acknowle dgement of the following:
• The adequacy and accuracy of the disclosu re in the filing is the responsibility
of the registrant.
Advanced 3-D Ultrasound Services, Inc.
Page 2
• The registrant acknowledges that staff comment or changes in response to
staff comment in the proposed disclosu re in the preliminary proxy materials
do not foreclose the Commission from taking any action with respect to the
filing.
• The registrant also represents that st aff comment may not be asserted 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
All persons who are by statute responsible for the adequacy and accuracy of the
information statement are urged to be certain that all information required pursuant to the
Securities Exchange Act of 1934 has b een included.
If you have any questions, please call Pa ul Fischer at (202) 551-3415 or the
undersigned at (202) 551-3694.
Sincerely,
Owen Pinkerton
Senior Counsel
Cc: Clifford Hunt, Esq.
By facsimile, 727-894-8002