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SEC Comment Letter for UBRANDIT COM (CIK 0001082384) — Oct 12, 2005

UBRANDIT COM (CIK 0001082384)
Date: Oct. 12, 2005 · CIK: 0001082384 · Accession: 0000000000-05-052156

AI Filing Summary & Sentiment

Date
October 12, 2005
Author
William Demarest
Form
UPLOAD
Company
UBRANDIT COM (CIK 0001082384)

Letter

Mail Stop 4561 October 12, 2005 Mr. Michael Anthony President UBRANDIT.COM 330 Clematis Street, Suite 217 West Palm Beach, FL 33401

RE: UBRANDIT.COM Form 8-K Filed October 11, 2005 File No. 1-15683

Dear Mr. Anthony:

We have reviewed your filing and have the following comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. We may ask you to provide us with information so we may better understand your disclosure. 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 comment or on any other aspect of our review. Feel free to call me at the telephone number listed at the end of this letter.

Form 8-K filed October 11, 2005

1. Please file a letter from your former accountant, indicating whether or not they agree with your disclosures in the Form 8-K. See Item 4.01 of Form 8-K and Item 304 of Regulation S-K.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that they have provided 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 comment, 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.

Please provide the supplemental information requested above within five business days from the date of this letter. The supplemental information should be filed as correspondence on EDGAR.

Any questions regarding the above should be directed to me at (202) 551-3432.

Sincerely,
William Demarest
Staff Accountant
??

Show Raw Text
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<TEXT>

Mail Stop 4561
      October 12, 2005

Mr. Michael Anthony
President
UBRANDIT.COM
330 Clematis Street, Suite 217
West Palm Beach, FL 33401

	RE:	UBRANDIT.COM
		Form 8-K
		Filed October 11, 2005
            	File No. 1-15683

Dear Mr. Anthony:

      We have reviewed your filing and have the following comment.
Where indicated, we think you should revise your document in
response
to this comment.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  We may
ask
you to provide us with information so we may better understand
your
disclosure.  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 comment or on any other
aspect
of our review.  Feel free to call me at the telephone number
listed
at the end of this letter.

Form 8-K filed October 11, 2005

1. Please file a letter from your former accountant, indicating
whether or not they agree with your disclosures in the Form 8-K.
See
Item 4.01 of Form 8-K and Item 304 of Regulation S-K.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that they
have
provided 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 comment, 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.

	Please provide the supplemental information requested above
within five business days from the date of this letter.  The
supplemental information should be filed as correspondence on
EDGAR.

      Any questions regarding the above should be directed to me
at
(202) 551-3432.

								Sincerely,

								William Demarest
								Staff Accountant
??

??

??

??

Mr. Michael Anthony
UBRANDIT.COM
October 12, 2005
Page 1

</TEXT>
</DOCUMENT>