SEC Company Response from MODTECH HOLDINGS INC (CIK 0001075066) — Jul 14, 2005
MODTECH HOLDINGS INC (CIK 0001075066)
Date: July 14, 2005 · CIK: 0001075066 · Accession: 0001193125-05-142431
AI Filing Summary & Sentiment
File numbers found in text: 000-25161
Referenced dates: April 18, 2005, July 11, 2005
Letter
Response Letter
Modtech Holdings, Inc.
2830 Barrett Avenue
Perris, CA 92751
July 14, 2005
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC. 20549-2000
Attn: Ryan Rohan
Re: Modtech Holdings, Inc.
Form 8-K Item 4.01 filed April 15,
Form 8-K/A Item 4.01 filed June 28, 2005
File # 000-25161
Ladies and Gentlemen:
The following response addresses the comments of the staff of the Securities and Exchange Commission (the “Commission”) set forth in the staff letter dated July 11, 2005 regarding the above-referenced Form 8-K filings of Modtech Holdings, Inc. (the “Company”). References to “comment” below correspond to the paragraph numbers of the staff’s letter.
Comments 1 & 2. The above-referenced Form 8-K filings do not indicate whether the audit committee of the board of directors recommended or approved the decision to change accountants because the Company did not make such a decision. The auditors advised the Company that they were resigning. The Form 8-K filed by the Company on May 5, 2005 reporting the engagement of Peterson & Company as the Company’s new auditors does state that the Audit Committee approved the decision to hire Peterson & Company.
Comment 3. In connection with the July 8, 2005 response on behalf of the Company to the Commission’s staff comment letter dated April 18, 2005 and in connection with this response to the Commission’s staff comment letter dated July 11, 2005, the Company acknowledges that
•
The Company is responsible for the adequacy and accuracy of the disclosure in the filing;
•
Staff comments or changes to disclosure in response to staff comments in the filing reviewed by the staff do not foreclose the Commission from taking action with respect to the filing; and
•
The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Sincerely,
/s/ David Buckley
Show Raw Text
CORRESP 1 filename1.htm Response Letter Modtech Holdings, Inc. 2830 Barrett Avenue Perris, CA 92751 July 14, 2005 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC. 20549-2000 Attn: Ryan Rohan Re: Modtech Holdings, Inc. Form 8-K Item 4.01 filed April 15, 2005 Form 8-K/A Item 4.01 filed June 28, 2005 File # 000-25161 Ladies and Gentlemen: The following response addresses the comments of the staff of the Securities and Exchange Commission (the “Commission”) set forth in the staff letter dated July 11, 2005 regarding the above-referenced Form 8-K filings of Modtech Holdings, Inc. (the “Company”). References to “comment” below correspond to the paragraph numbers of the staff’s letter. Comments 1 & 2. The above-referenced Form 8-K filings do not indicate whether the audit committee of the board of directors recommended or approved the decision to change accountants because the Company did not make such a decision. The auditors advised the Company that they were resigning. The Form 8-K filed by the Company on May 5, 2005 reporting the engagement of Peterson & Company as the Company’s new auditors does state that the Audit Committee approved the decision to hire Peterson & Company. Comment 3. In connection with the July 8, 2005 response on behalf of the Company to the Commission’s staff comment letter dated April 18, 2005 and in connection with this response to the Commission’s staff comment letter dated July 11, 2005, the Company acknowledges that • The Company is responsible for the adequacy and accuracy of the disclosure in the filing; • Staff comments or changes to disclosure in response to staff comments in the filing reviewed by the staff do not foreclose the Commission from taking action with respect to the filing; and • The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Sincerely, /s/ David Buckley David Buckley Chief Executive Officer