SEC Company Response from AlphaTON Capital Corp (ALP) (CIK 0001095435) (ALP) — May 16, 2005
AlphaTON Capital Corp (ALP) (CIK 0001095435)
Date: May 16, 2005 · CIK: 0001095435 · Accession: 0001095435-05-000016
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-123533
Referenced dates: April 22, 2005
Letter
Blank document-portrait
Messerli & Kramer P.A.
150 South Fifth Street, Suite 1800
Minneapolis, Minnesota 55402
Via EDGAR
May 16, 2005
U.S. Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549-0405
Re:
Bontan Corporation (the "Company")
Amendment No. 2 to Registration Statement on Form F-3
SEC File No. 333-123533
Ladies and Gentlemen:
With this letter, we are (i) filing Amendment No. 2 to the above Registration Statement containing changes as requested by the Staff in telephone calls, and (ii) providing additional supplemental information regarding comment no. 2 contained in the Staff’s comment letter dated April 22, 2005.
With respect to comment no. 2, supplementally, we advise the Staff that no selling shareholder is a registered-broker dealer or affiliate of a registered broker-dealer in the United States. However, two selling shareholders are registered broker-dealers under Quebec laws; namely, David M. Glazer and Robert Mendel. Messrs. Glazer and Mendel represented to the Company that they purchased the Company's securities which are the subject of the registration statement for their own (or their affiliate's) behalf in the ordinary course of business, and at the time of purchase of such securities, they had no agreement, undertaking, arrangement, obligation or commitment, directly or indirectly, with any party to distribute the securities.
The Company has added the foregoing information to page 14 of the Registration Statement.
Please contact the undersigned regarding this filing at 612-672-3765. Thank you for your prompt attention to our filing.
U.S. Securities and Exchange Commission
May 16, 2005
Page 2
Very truly yours,
/s/ Pamela A. Curran
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CORRESP 1 filename1.htm Blank document-portrait Messerli & Kramer P.A. 150 South Fifth Street, Suite 1800 Minneapolis, Minnesota 55402 Via EDGAR May 16, 2005 U.S. Securities and Exchange Commission 450 Fifth Street N.W. Washington, D.C. 20549-0405 Re: Bontan Corporation (the "Company") Amendment No. 2 to Registration Statement on Form F-3 SEC File No. 333-123533 Ladies and Gentlemen: With this letter, we are (i) filing Amendment No. 2 to the above Registration Statement containing changes as requested by the Staff in telephone calls, and (ii) providing additional supplemental information regarding comment no. 2 contained in the Staff’s comment letter dated April 22, 2005. With respect to comment no. 2, supplementally, we advise the Staff that no selling shareholder is a registered-broker dealer or affiliate of a registered broker-dealer in the United States. However, two selling shareholders are registered broker-dealers under Quebec laws; namely, David M. Glazer and Robert Mendel. Messrs. Glazer and Mendel represented to the Company that they purchased the Company's securities which are the subject of the registration statement for their own (or their affiliate's) behalf in the ordinary course of business, and at the time of purchase of such securities, they had no agreement, undertaking, arrangement, obligation or commitment, directly or indirectly, with any party to distribute the securities. The Company has added the foregoing information to page 14 of the Registration Statement. Please contact the undersigned regarding this filing at 612-672-3765. Thank you for your prompt attention to our filing. U.S. Securities and Exchange Commission May 16, 2005 Page 2 Very truly yours, /s/ Pamela A. Curran Pamela A. Curran Messerli & Kramer P.A. 150 South Fifth Street, Suite 1800 Minneapolis MN 55402 612 672 3765 (direct) pcurran@mandklaw.com