SEC Company Response from PACIFIC MAGTRON INTERNATIONAL CORP (CIK 0001077050) — Jun 23, 2005
PACIFIC MAGTRON INTERNATIONAL CORP (CIK 0001077050)
Date: June 23, 2005 · CIK: 0001077050 · Accession: 0001144204-05-019711
AI Filing Summary & Sentiment
Referenced dates: June 17, 2005
Letter
Re: Pacific Magtron International Corp. Form 10-K for Fiscal Year Ended December 31, 2004 Filed April 21, 2005 File No. 0-25277
PACIFIC MAGTRON INTERNATIONAL CORP. 1600 California Circle Milipitas, California 95035
June 23, 2005
Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549
Attention: Stephen G. Krikorian, Accounting Branch Chief Tamara Tangen, Staff Accountant
Ladies and Gentlemen:
On behalf of Pacific Magtron International Corp., a Nevada corporation (the "Company"), we hereby transmit for filing, pursuant to Rule 12b-15 under the Securities Exchange Act of 1934, as amended, and Rule 101(a) of the Commission's Regulation S-T, Amendment No. 1 to the Company's Annual Report on Form 10-K for the fiscal year ended December 31, 2004 (the "Form 10-K/A").
Set forth below are the Company's responses to the comments of the Staff with respect to the above-referenced filing, as outlined in the letter dated June 17, 2005 (the "Comment Letter") addressed to Martin Nielson, Chief Executive Officer of the Company. The numbered paragraphs below correspond to the numbered paragraphs in the Comment Letter to indicate the manner in which the Company has responded to the Staff's comments.
1. The failure to file the Section 906 Certification of the Company's Chief Financial Officer with the Annual Report on Form 10-K for the year ended December 31, 2004 was inadvertent and unintentional. The Chief Financial Officer's Section 906 Certification is filed with the Form 10-K/A as Exhibit 32.2. In addition, as the Form 10-K/A amends the Company's previous filing in its entirety, the Form 10-K/A includes as exhibits new Section 302 Certifications by the Chief Executive Officer and the Chief Financial Officer and a new Section 906 Certification by the Chief Executive Officer.
In connection with the Staff's request in the Comment Letter that the Company provide a statement containing certain acknowledgements, the Company acknowledges that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in the filing; (ii) staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and (iii) the Company may not assert staff
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comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you have any questions about this letter or the Form 10-K/A, please do not hesitate to call me at (408) 956-8888.
Very truly yours,
/s/ Martin Neilson
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PACIFIC MAGTRON INTERNATIONAL CORP.
1600 California Circle
Milipitas, California 95035
June 23, 2005
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Stephen G. Krikorian, Accounting Branch Chief
Tamara Tangen, Staff Accountant
Re: Pacific Magtron International Corp.
Form 10-K for Fiscal Year Ended December 31, 2004
Filed April 21, 2005
File No. 0-25277
Ladies and Gentlemen:
On behalf of Pacific Magtron International Corp., a Nevada corporation (the
"Company"), we hereby transmit for filing, pursuant to Rule 12b-15 under the
Securities Exchange Act of 1934, as amended, and Rule 101(a) of the Commission's
Regulation S-T, Amendment No. 1 to the Company's Annual Report on Form 10-K for
the fiscal year ended December 31, 2004 (the "Form 10-K/A").
Set forth below are the Company's responses to the comments of the Staff with
respect to the above-referenced filing, as outlined in the letter dated June 17,
2005 (the "Comment Letter") addressed to Martin Nielson, Chief Executive Officer
of the Company. The numbered paragraphs below correspond to the numbered
paragraphs in the Comment Letter to indicate the manner in which the Company has
responded to the Staff's comments.
1. The failure to file the Section 906 Certification of the Company's Chief
Financial Officer with the Annual Report on Form 10-K for the year ended
December 31, 2004 was inadvertent and unintentional. The Chief Financial
Officer's Section 906 Certification is filed with the Form 10-K/A as Exhibit
32.2. In addition, as the Form 10-K/A amends the Company's previous filing in
its entirety, the Form 10-K/A includes as exhibits new Section 302
Certifications by the Chief Executive Officer and the Chief Financial Officer
and a new Section 906 Certification by the Chief Executive Officer.
In connection with the Staff's request in the Comment Letter that the Company
provide a statement containing certain acknowledgements, the Company
acknowledges that: (i) the Company is responsible for the adequacy and accuracy
of the disclosure in the filing; (ii) staff comments or changes to disclosure in
response to staff comments do not foreclose the Commission from taking any
action with respect to the filing; and (iii) the Company may not assert staff
<PAGE>
comments as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.
If you have any questions about this letter or the Form 10-K/A, please do not
hesitate to call me at (408) 956-8888.
Very truly yours,
/s/ Martin Neilson
Martin Neilson
Chief Executive Officer
cc: Gary A. Miller, Esq.
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