SEC Comment Letter for StableX Technologies, Inc. (FABC) (CIK 0001086745) (FABC) — Apr 10, 2014
StableX Technologies, Inc. (FABC) (CIK 0001086745)
Date: April 10, 2014 · CIK: 0001086745 · Accession: 0000000000-14-018313
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34643
Referenced dates: March 18, 2014
Letter
April 10, 2014 Via E -mail Joseph A. Heater Chief Financial Officer WPCS International Incorporated One East Uwchlan Avenue, Suite 301 Exton, PA 19341
Re: WPCS International Incorporated Revised Preliminary Proxy Statement on Schedule 14A Filed March 7, 2014 Response dated April 1, 2014 File No. 001-34643
Dear Mr. Heater :
We have reviewed your filing an d have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested respons e. If you do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments.
General
1. We note your responses to our comment letter dated March 18, 2014 including your response to comment 1 explaining the use of the term “new line of business” when discussing the acquisit ion of BTX Trader. Please revise your preliminary proxy to make clear that BTX Trader is not yet a new line of business, but rather the entity is limited to consisting of “a software technology asset.”
Joseph A. Heater WPCS International Incorporated April 10, 2014 Page 2
Please contact Christine Adams, Staff Accountant, at 202 -551-3363 or Carlos Pacho, Senior Assistant Chief Accountant, at 202 -551-3835 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp, Attorney - Advis or, at 202-551-6971 or Celeste M. Murphy, Legal Branch Chief, at 202-551-3257 with any other questions.
Sincerely,
/s/ Celeste M. Murphy for
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April 10, 2014 Via E -mail Joseph A. Heater Chief Financial Officer WPCS International Incorporated One East Uwchlan Avenue, Suite 301 Exton, PA 19341 Re: WPCS International Incorporated Revised Preliminary Proxy Statement on Schedule 14A Filed March 7, 2014 Response dated April 1, 2014 File No. 001-34643 Dear Mr. Heater : We have reviewed your filing an d have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested respons e. If you do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. General 1. We note your responses to our comment letter dated March 18, 2014 including your response to comment 1 explaining the use of the term “new line of business” when discussing the acquisit ion of BTX Trader. Please revise your preliminary proxy to make clear that BTX Trader is not yet a new line of business, but rather the entity is limited to consisting of “a software technology asset.” Joseph A. Heater WPCS International Incorporated April 10, 2014 Page 2 Please contact Christine Adams, Staff Accountant, at 202 -551-3363 or Carlos Pacho, Senior Assistant Chief Accountant, at 202 -551-3835 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp, Attorney - Advis or, at 202-551-6971 or Celeste M. Murphy, Legal Branch Chief, at 202-551-3257 with any other questions. Sincerely, /s/ Celeste M. Murphy for Larry Spirgel Assistant Director cc: Via E -mail James M. Turner, Esq. Sichenzia Ross Friedman Ference LLP