SEC Comment Letter for DIVERSIFIED PRODUCT INSPECTIONS INC (CIK 0001079297) — Jul 7, 2005
DIVERSIFIED PRODUCT INSPECTIONS INC (CIK 0001079297)
Date: July 7, 2005 · CIK: 0001079297 · Accession: 0000000000-05-034500
AI Filing Summary & Sentiment
File numbers found in text: 000-25429
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Via Facsimile and U.S. Mail
Mail Stop 6010
July 7, 2005
Mr. John Van Zyll
President, Chief Executive Officer and Chairman
Diversified Product Inspections, Inc.
1059 East Tri-County Blvd.
Oliver Springs, TN 37830
Re: Diversified Product Inspections, Inc.
Form 10-KSB for the Fiscal Year Ended December 31, 2004
Filed March 29, 2005
File No. 000-25429
Dear Mr. Van Zyll:
We have limited our review of your filing to those issues we
have addressed in our comments. In our comments, we may ask you
to
provide us with information so we may better understand your
disclosure. Please be as detailed as necessary in your
explanation.
After reviewing this information, we may raise additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Item 7. Financial Statements.
Notes to Financial Statements, page F-7
2. Convertible Debt and Equity Line of Credit Agreement, page F-9
1. Please tell us how your immediate recognition, in 2002, of the
beneficial conversion feature complied with paragraphs 19 and 20
of
EITF 00-27. In so doing, please tell us whether the convertible
debt
had stated redemption dates and, if so, what those dates were. In
addition, please tell us how your apparent lack of a charge, in
2004,
related to the beneficial conversion feature complied with
paragraph
21 of EITF 00-27.
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
letter that keys your responses to our comments and provide the
requested information. Detailed letters greatly facilitate our
review. Please file your letter on EDGAR under the form type
label
CORRESP. Please understand that we may have additional comments
after reviewing your responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging 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 do not foreclose the Commission from taking any 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Tabatha Akins, Staff Accountant, at (202)
551-
3658 or Oscar Young, Senior Staff Accountant, at (202) 551-3622 if
you have questions regarding comments on the financial statements
and
related matters. Please contact me at (202) 551-3679 with any
other
questions.
Sincerely,
for Jim B. Rosenberg
Senior Assistant Chief
Accountant
??
??
??
??
John Van Zyll
Diversified Product Inspections, Inc.
July 7, 2005
Page 1
</TEXT>
</DOCUMENT>