SEC Company Response from SUN NEW MEDIA INC. (NXMR) (CIK 0001088005) — Mar 31, 2005
SUN NEW MEDIA INC. (NXMR) (CIK 0001088005)
Date: March 31, 2005 · CIK: 0001088005 · Accession: 0001221508-05-000020
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 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 receive preliminary approval only of all of the items, but not go forward with any of the proposed changes at this time. All items would be subject to the stockholders of the Company reconfirming each item individually 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 any of the proposed items until stockholder approval has been reconfirmed 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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Response Letter
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 31, 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 receive preliminary approval only
of all of the items, but not go forward with any of the proposed changes at this
time. All items would be subject to the stockholders of the Company reconfirming
each item individually 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 any of the proposed items until stockholder approval has been
reconfirmed 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.