SEC Comment Letter for ROO GROUP INC (CIK 0001076700) — Sep 1, 2005
ROO GROUP INC (CIK 0001076700)
Date: Sept. 1, 2005 · CIK: 0001076700 · Accession: 0000000000-05-045555
AI Filing Summary & Sentiment
Letter
Mail Stop 6010 September 1, 2005 Robert Petty Chief Executive Officer ROO Group, Inc. 228 East 45th Street, 8th Floor New York, NY 10017
Re: ROO Group, Inc. Preliminary Information Statement on Schedule 14A, Filed August 24, 2004 File No. 0-25659
Dear Mr. Petty:
This is to advise you that we have limited our review of the above referenced information statement to only the issues identified below.
Schedule 14C 1. Please revise your disclosure to indicate whether the reverse stock split could cause the number of shareholders to fall below shareholders. If so, please so indicate and also provide disclosure as to the consequences of falling below the 300 shareholder threshold. 2. Please revise your disclosure to include language of any current plan or commitment, or lack thereof, of the board to issue any of the "additional" common stock that will be available for future issuance after the reverse stock split.
* * *
You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a response letter with your amendment that keys your responses to our comments. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR under the form type label CORRESP. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
Please contact Song P. Brandon at (202) 551-3621 with any other questions.
Sincerely,
Jeffrey P. Riedler
Assistant Director
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<TEXT>
Mail Stop 6010
September 1, 2005
Robert Petty
Chief Executive Officer
ROO Group, Inc.
228 East 45th Street, 8th Floor
New York, NY 10017
Re: ROO Group, Inc.
Preliminary Information Statement on Schedule 14A, Filed
August
24, 2004
File No. 0-25659
Dear Mr. Petty:
This is to advise you that we have limited our review of the
above referenced information statement to only the issues
identified
below.
Schedule 14C
1. Please revise your disclosure to indicate whether the reverse
stock split could cause the number of shareholders to fall below
300
shareholders. If so, please so indicate and also provide
disclosure
as to the consequences of falling below the 300 shareholder
threshold.
2. Please revise your disclosure to include language of any
current
plan or commitment, or lack thereof, of the board to issue any of
the
"additional" common stock that will be available for future
issuance
after the reverse stock split.
* * *
You may wish to provide us with marked copies of the amendment to
expedite our review. Please furnish a response letter with your
amendment that keys your responses to our comments. Detailed
cover
letters greatly facilitate our review. Please file your cover
letter
on EDGAR under the form type label CORRESP. Please understand
that
we may have additional comments after reviewing your amendment and
responses to our comments.
Please contact Song P. Brandon at (202) 551-3621 with any
other
questions.
Sincerely,
Jeffrey P. Riedler
Assistant Director
??
??
??
??
</TEXT>
</DOCUMENT>