SEC Company Response from NETWORK INSTALLATION CORP (CIK 0001069778) — Sep 12, 2005
NETWORK INSTALLATION CORP (CIK 0001069778)
Date: Sept. 12, 2005 · CIK: 0001069778 · Accession: 0001231742-05-000578
AI Filing Summary & Sentiment
Letter
RE: Network Installation Corporation Form 8-K filed February 18, 2005 File No. 0-25499
Trombly Business Law 1163 Walnut Street, Suite 7, Newton, MA 02461 Telephone (617) 243-0060 Facsimile (309) 406-1426
Amy M. Trombly, Esq. amy@tromblybusinesslaw.com
September 12, 2005
Delivered by electronic submission via EDGAR
United States Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, DC 20549
Attn: Inessa Berenbaum
Ladies and Gentlemen:
On behalf of Network Installation Corporation (the "Company"), I am responding to oral comments received from the staff of the Securities and Exchange Commission (the "Staff") regarding the Company's Form 8-K filed on February 18, 2005. Set forth below are the Company's responses to the Staff's comments.
Comment 1. -----------
Please provide disclosures with respect to a change in accountants for the two most recent fiscal years. Please revise the filing to provide disclosures with respect to disagreements and audit reports covering two fiscal years.
Response 1. ------------
The Company respectfully notes that Instruction 1 to Item 304 states the disclosure called for by paragraph (a) of Item 304 need not be provided if it has been previously reported as that term is defined in Rule 12b-2 under the Exchange Act. The Company previously filed a Form 8-K describing the change in auditors on May 4, 2004 that covers the time period questioned by the Staff.
Comment 2. -----------
Please revise the Form 8-K to include information regarding the going concern opinion.
Response 2. ------------
The Company respectfully notes that Instruction 1 to Item 304 states the disclosure called for by paragraph (a) of Item 304 need not be provided if it has been previously reported as that term is defined in Rule 12b-2 under the Exchange Act. The Company previously filed a Form 8-K describing the change in auditors on May 4, 2004 that covers the time period questioned by the Staff. That Form 8-K disclosed that the Company had a going concern opinion for the fiscal years ended December 31, 2002 and December 31, 2003. The 8-K that the Staff commented on was filed on February 11, 2005. At that time, the Company had not yet filed its 10-KSB for the fiscal year ended December 31, 2004. Therefore, the Company believes it could not have disclosed information about a going concern opinion for the year ended December 31, 2004.
The Company has not amended the Form 8-K because it believes all required disclosure was provided either in the 8-K filed on May 4, 2004 or the 8-K filed on February 11, 2005. Please call the undersigned with any questions or comments regarding this letter, the Current Report on Form 8-K or other matters related to the filing.
Regards,
/s/ Amy Trombly, Esq.
Show Raw Text
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Trombly Business Law
1163 Walnut Street, Suite 7, Newton, MA 02461
Telephone (617) 243-0060
Facsimile (309) 406-1426
Amy M. Trombly, Esq. amy@tromblybusinesslaw.com
September 12, 2005
Delivered by electronic submission via EDGAR
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, DC 20549
Attn: Inessa Berenbaum
RE: Network Installation Corporation
Form 8-K filed February 18, 2005
File No. 0-25499
Ladies and Gentlemen:
On behalf of Network Installation Corporation (the "Company"), I am responding
to oral comments received from the staff of the Securities and Exchange
Commission (the "Staff") regarding the Company's Form 8-K filed on February 18,
2005. Set forth below are the Company's responses to the Staff's comments.
Comment 1.
-----------
Please provide disclosures with respect to a change in accountants for the two
most recent fiscal years. Please revise the filing to provide disclosures with
respect to disagreements and audit reports covering two fiscal years.
Response 1.
------------
The Company respectfully notes that Instruction 1 to Item 304 states the
disclosure called for by paragraph (a) of Item 304 need not be provided if it
has been previously reported as that term is defined in Rule 12b-2 under the
Exchange Act. The Company previously filed a Form 8-K describing the change in
auditors on May 4, 2004 that covers the time period questioned by the Staff.
Comment 2.
-----------
Please revise the Form 8-K to include information regarding the going concern
opinion.
Response 2.
------------
The Company respectfully notes that Instruction 1 to Item 304 states the
disclosure called for by paragraph (a) of Item 304 need not be provided if it
has been previously reported as that term is defined in Rule 12b-2 under the
Exchange Act. The Company previously filed a Form 8-K describing the change in
auditors on May 4, 2004 that covers the time period questioned by the Staff.
That Form 8-K disclosed that the Company had a going concern opinion for the
fiscal years ended December 31, 2002 and December 31, 2003. The 8-K that the
Staff commented on was filed on February 11, 2005. At that time, the Company
had not yet filed its 10-KSB for the fiscal year ended December 31, 2004.
Therefore, the Company believes it could not have disclosed information about a
going concern opinion for the year ended December 31, 2004.
The Company has not amended the Form 8-K because it believes all required
disclosure was provided either in the 8-K filed on May 4, 2004 or the 8-K filed
on February 11, 2005. Please call the undersigned with any questions or comments
regarding this letter, the Current Report on Form 8-K or other matters related
to the filing.
Regards,
/s/ Amy Trombly, Esq.
Amy Trombly, Esq.
cc: Jeffrey Hultman, Network Installation Corporation
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