SEC Comment Letter for Global General Technologies, Inc. (CIK 0001092455) — Sep 29, 2005
Global General Technologies, Inc. (CIK 0001092455)
Date: Sept. 29, 2005 · CIK: 0001092455 · Accession: 0000000000-05-050313
AI Filing Summary & Sentiment
File numbers found in text: 000-28417
Letter
Mail Stop 4561 VIA U.S. MAIL AND FAX (925) 955-0800 Mr. Shmuel Shneibalg President Knowledge Transfer Systems, Inc. 5509 11th Avenue Brooklyn, NY 11219
Re: Knowledge Transfer Systems, Inc. Form 10-KSB for the year ended December 31, 2004 Filed April 13, 2005 Form 10-QSB for the quarter ended June 30, 2005 Filed August 18, 2005 File No. 000-28417
Dear Mr. Shneibalg:
We have reviewed your September 27, 2005 response letter and have the following additional comments.
1. We read your response to comment 1 and understand that you plan to record the fair value of services performed based on the quoted market price of $0.0065 on May 21, 2004. We also note that the quoted market price of $0.0065 was the price of your common stock prior to the 500 to 1 reverse stock split on July 29, 2004 and the 2.3 million shares issued in October 2004 were on a post split basis. Please further explain to us why you are using the quoted market price of your common stock on a pre-split basis to value this transaction.
2. Please tell us the closing date of the stock purchase agreement where you issued 2.3 million shares and your basis for using a measurement date as of the original Share Purchase Agreement. In your response, please explain to us what events took place between May 21, 2004 and October 12, 2004 when the shares were issued. Please cite the relevant accounting literature that supports your accounting. Refer to paragraphs 18 - 22 of SFAS 123 and EITF 96- 18, as applicable.
3. We read your response to comment 2. Please tell us why you have recorded an immediate interest expense associated with the beneficial conversion feature on your convertible debt that has a two-year term rather than amortize the discount over the term of the convertible instrument. Refer to Issue 6 in EITF 00-27.
* * * *
You may contact Josh Forgione, at (202) 551-3431, or me, at (202) 551-3403, if you have questions. Please respond to the comments included in this letter within 10 business days or tell us when you will provide us with a response. Please file your response on EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
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September 29, 2005
Mail Stop 4561
VIA U.S. MAIL AND FAX (925) 955-0800
Mr. Shmuel Shneibalg
President
Knowledge Transfer Systems, Inc.
5509 11th Avenue
Brooklyn, NY 11219
Re: Knowledge Transfer Systems, Inc.
Form 10-KSB for the year ended December 31, 2004
Filed April 13, 2005
Form 10-QSB for the quarter ended June 30, 2005
Filed August 18, 2005
File No. 000-28417
Dear Mr. Shneibalg:
We have reviewed your September 27, 2005 response letter and
have the following additional comments.
1. We read your response to comment 1 and understand that you plan
to
record the fair value of services performed based on the quoted
market price of $0.0065 on May 21, 2004. We also note that the
quoted market price of $0.0065 was the price of your common stock
prior to the 500 to 1 reverse stock split on July 29, 2004 and the
2.3 million shares issued in October 2004 were on a post split
basis.
Please further explain to us why you are using the quoted market
price of your common stock on a pre-split basis to value this
transaction.
2. Please tell us the closing date of the stock purchase agreement
where you issued 2.3 million shares and your basis for using a
measurement date as of the original Share Purchase Agreement. In
your response, please explain to us what events took place between
May 21, 2004 and October 12, 2004 when the shares were issued.
Please cite the relevant accounting literature that supports your
accounting. Refer to paragraphs 18 - 22 of SFAS 123 and EITF 96-
18,
as applicable.
3. We read your response to comment 2. Please tell us why you
have
recorded an immediate interest expense associated with the
beneficial
conversion feature on your convertible debt that has a two-year
term
rather than amortize the discount over the term of the convertible
instrument. Refer to Issue 6 in EITF 00-27.
* * * *
You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within 10 business days or tell us when
you
will provide us with a response. Please file your response on
EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
??
??
??
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Mr. Shmuel Shneibalg
Knowledge Transfer Systems, Inc.
September 29, 2005
Page 1
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