SEC Company Response from FUSION TELECOMMUNICATIONS INTERNATIONAL INC (CIK 0001071411) — Feb 11, 2005
FUSION TELECOMMUNICATIONS INTERNATIONAL INC (CIK 0001071411)
Date: Feb. 11, 2005 · CIK: 0001071411 · Accession: 0000930413-05-000941
AI Filing Summary & Sentiment
File numbers found in text: 333-120412
Letter
GERSTEN, SAVAGE, KAPLOWITZ, WOLF & MARCUS, LLP 600 LEXINGTON AVENUE NEW YORK, NEW YORK 10022 February 11, 2005 United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Cheryl Grant, Esq.
RE: FUSION TELECOMMUNICATIONS INTERNATIONAL, INC. FILE NO, 333-120412
Dear Ms. Grant:
Please see our responses to your written comments of February 11, 2005.
Response #1:
As the Company stated, they track off-net revenues by customer and product. The Company tracks off-net costs of revenues by provider (vendor). This tracking analysis is consistent with the disclosure in the book.
Response #2:
Please note that the Company believes that it was operating within the statute and notes the fact that it represented a very small amount of revenues. More importantly, the Company does not believe that the fact that Efonica had dealings with Libya during the time that Libya was both identified as a state sponsor of terrorism and subject to OFAC-administered economic sanctions raises any risk that it would have a potential impact on Fusion's reputation and share value that would cause Efonica's relationship with the Libyan reseller to be material to Fusion or pose a material risk to Fusion's security holders, especially considering the current status of the United State's relationship with Libya.
Sincerely,
\s\ Arthur S. Marcus, Esq.
--------------------------
Arthur S. Marcus, Esq.
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GERSTEN, SAVAGE, KAPLOWITZ, WOLF & MARCUS, LLP
600 LEXINGTON AVENUE
NEW YORK, NEW YORK 10022
February 11, 2005
United States
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Cheryl Grant, Esq.
RE: FUSION TELECOMMUNICATIONS INTERNATIONAL, INC.
FILE NO, 333-120412
Dear Ms. Grant:
Please see our responses to your written comments of February 11, 2005.
Response #1:
As the Company stated, they track off-net revenues by customer
and product. The Company tracks off-net costs of revenues by provider
(vendor). This tracking analysis is consistent with the disclosure in
the book.
Response #2:
Please note that the Company believes that it was operating
within the statute and notes the fact that it represented a very small
amount of revenues. More importantly, the Company does not believe that
the fact that Efonica had dealings with Libya during the time that
Libya was both identified as a state sponsor of terrorism and subject
to OFAC-administered economic sanctions raises any risk that it would
have a potential impact on Fusion's reputation and share value that
would cause Efonica's relationship with the Libyan reseller to be
material to Fusion or pose a material risk to Fusion's security
holders, especially considering the current status of the United
State's relationship with Libya.
Sincerely,
\s\ Arthur S. Marcus, Esq.
--------------------------
Arthur S. Marcus, Esq.
</TEXT>
</DOCUMENT>