SEC Company Response from SUN NEW MEDIA INC. (NXMR) (CIK 0001088005) — Mar 30, 2005
SUN NEW MEDIA INC. (NXMR) (CIK 0001088005)
Date: March 30, 2005 · CIK: 0001088005 · Accession: 0001221508-05-000016
AI Filing Summary & Sentiment
Referenced dates: March 1, 2005, March 21, 2005, March 9, 2005
Letter
Attention: Owen Pinkerton and Elaine Wolff Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549
Dear Mr. Pinkerton and Ms. Wolff,
Re: SE Global Equities Corp. - Pre Schedule 14C - File No. 0-26347
Thank-you for your letter dated March 21, 2005, concerning our response letter dated March 9, 2005 to your letter dated March 1, 2005 concerning the preliminary information statement filed by SE Global Equities Corp (the "Company") on Schedule 14A on February 8, 2005 and its subsequent filing of a new preliminary information statement filed on March 1, 2005.
As discussed with Mr. Pinkerton by telephone March 30, 2005, the Company will be submitting a new information circular for a new meeting where the stockholders of the Company will be asked to approve the proposed transaction with Asia Multi-Media Technology Services Holdings Limited ("AMMT-BVI"). The transaction is currently being restructured as a stock purchase versus an asset purchase transaction. At this second meeting, the Company will be seeking stockholder approval for this transaction. The new information circular will incorporate pro forma financial statements and audited financial statements of the Company and AMMT-BVI and all other required disclosure for such a transaction under Schedule 14A.
As discussed with Mr. Pinkerton, it is the intent of the Company at the meeting to be held March 31, 2005, to abandon all items proposed at the meeting but the reverse stock split. The Company wishes to go forward with obtaining preliminary approval for the reverse stock split subject to the stockholders of the Company reconfirming the reverse stock split at the second meeting where the stockholder will be asked to approve the transaction with AMMT-BVI. The Company will take no steps to go forward with the reverse stock split until this item has been reconfirmed by the stockholders at the second meeting. As stated above, the information circular for this second meeting will contain full disclosure of the transaction and include audited financial statements of the Company and AMMT-BVI, and pro forma combined financial statements. The Company will issue a press release regarding the actions taken (or more appropriately not taken) at this meeting and the requirement of a reconfirmation of the reverse stock split at the second meeting.
We trust you will find the foregoing is satisfactory.
Yours Truly,
VENTURE LAW CORPORATION
/s/ Alixe Cormick
Per:
Alixe Cormick
c. SE Global Equities Corp.
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CORRESP
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VENTURE LAW CORPORATION
VENTURE LAW CORPORATION
Suite 618 - 688 West Hastings Street
Vancouver, British Columbia, V6B 1P1
Telephone: (604) 659-9188
Facsimile: (604) 659-9178
Alixe B. Cormick
Direct Line: (604) 659-9181
March 30, 2005
BY EDGAR
Attention: Owen
Pinkerton and Elaine Wolff
Division of
Corporation Finance
Securities and
Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
0405
Dear Mr. Pinkerton and Ms. Wolff,
Re:
SE Global Equities Corp. - Pre Schedule 14C - File No. 0-26347
Thank-you for your
letter dated March 21, 2005, concerning our response letter dated March 9, 2005
to your letter dated March 1, 2005 concerning the preliminary information
statement filed by SE Global Equities Corp (the "Company") on Schedule 14A on
February 8, 2005 and its subsequent filing of a new preliminary information
statement filed on March 1, 2005.
As discussed with
Mr. Pinkerton by telephone March 30, 2005, the Company will be submitting a new
information circular for a new meeting where the stockholders of the Company
will be asked to approve the proposed transaction with Asia Multi-Media
Technology Services Holdings Limited ("AMMT-BVI"). The transaction is currently
being restructured as a stock purchase versus an asset purchase transaction. At
this second meeting, the Company will be seeking stockholder approval for this
transaction. The new information circular will incorporate pro forma financial
statements and audited financial statements of the Company and AMMT-BVI and all
other required disclosure for such a transaction under Schedule 14A.
As discussed with
Mr. Pinkerton, it is the intent of the Company at the meeting to be held March
31, 2005, to abandon all items proposed at the meeting but the reverse stock
split. The Company wishes to go forward with obtaining preliminary approval for
the reverse stock split subject to the stockholders of the Company reconfirming
the reverse stock split at the second meeting where the stockholder will be
asked to approve the transaction with AMMT-BVI. The Company will take no steps
to go forward with the reverse stock split until this item has been reconfirmed
by the stockholders at the second meeting. As stated above, the information
circular for this second meeting will contain full disclosure of the transaction
and include audited financial statements of the Company and AMMT-BVI, and pro
forma combined financial statements. The Company will issue a press release
regarding the actions taken (or more appropriately not taken) at this meeting
and the requirement of a reconfirmation of the reverse stock split at the second
meeting.
We trust you will
find the foregoing is satisfactory.
Yours Truly,
VENTURE LAW CORPORATION
/s/ Alixe Cormick
Per:
Alixe Cormick
c. SE Global Equities Corp.