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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

Date
Oct. 21, 2005
Author
/s/JOHN
Form
CORRESP
Company
COSINE COMMUNICATIONS INC (CIK 0001060824)

Letter

VIA EDGAR AND OVERNIGHT DELIVERY United States Securities and Exchange Commission Division of Corporate Finance Attention: Mark P. Shuman Re: CoSine Communications, Inc. Preliminary Proxy Statement on Schedule 14A filed October 6, 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

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

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