SEC Company Response from COSINE COMMUNICATIONS INC (CIK 0001060824) — Oct 21, 2005
COSINE COMMUNICATIONS INC (CIK 0001060824)
Date: Oct. 21, 2005 · CIK: 0001060824 · Accession: 0001144204-05-032299
AI Filing Summary & Sentiment
Referenced dates: October 18, 2005
Show Raw Text
CORRESP
1
filename1.htm
COLLETTE
ERICKSON
FARMER
&O’NEILL
LLP
ATTORNEYS
AT LAW
235
PINE STREET, SUITE
1300
SAN
FRANCISCO, CALIFORNIA 94104-2733
TELEPHONE
(415) 788-4646 ·
FAX (415) 788-6929 ·
www.collette.com
October
21, 2005
VIA
EDGAR AND OVERNIGHT DELIVERY
United
States Securities and Exchange Commission
Division
of Corporate Finance
100
F
Street, NE
Washington,
D.C. 20549
Attention: Mark
P.
Shuman
Sara
Kalin
Re:
CoSine
Communications, Inc.
Preliminary
Proxy Statement on Schedule 14A filed October 6,
2005
File
No. 0-30715
Dear
Mr.
Shuman:
On
behalf
of CoSine Communications, Inc. (the "Company"), we submit this letter in
response to comments from the Staff of the Securities and Exchange Commission
received by letter dated October 18, 2005, relating to the Company's Preliminary
Proxy Statement on Schedule 14A (File No. 0-30715) filed with the
Commission on October 6, 2005.
In
this
letter, we have recited the comments from the Staff in italicized, bold type
and
have followed each comment with the Company's response.
General
We
note from your Form 10-K for the fiscal year ended December 31, 2004 that
you
have a subsidiary in Korea. Please confirm that such subsidiary is in South
Korea or advise.
The
Company appreciates the Staff’s comments and will provide such clarification and
disclosure in its future filings. For the Staff’s information, the Company's
subsidiary, CoSine Communications Korea, was organized and existed under
the
laws of the country of South Korea, officially the Republic of Korea. CoSine
Communications Korea was liquidated as of September 7, 2005.
*
*
*
U.S.
Securities and Exchange Commission
October
21, 2005
Page
2
Please
note that the acknowledgments of the Company as requested by the Staff are
provided under separate cover.
Please
direct your questions or comments regarding the Company's responses to the
undersigned at (415) 788-4646. Thank you for your assistance.
Sincerely,
/s/JOHN
V. ERICKSON
John
V.
Erickson
cc: Terry
Gibson