SEC Company Response from AlphaTON Capital Corp (ALP) (CIK 0001095435) (ALP) — Jan 17, 2006
AlphaTON Capital Corp (ALP) (CIK 0001095435)
Date: Jan. 17, 2006 · CIK: 0001095435 · Accession: 0001095435-06-000002
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 9, 2005
Letter
100 F Street, NE Washington, D.C. 20549-7410 USA By fax sent to Jennifer Goeken – Division of Corporation Finance (also filed on EDGAR)
Dear Jill S. Davis:
RE: BONTAN CORPORATION INC. – Form 20-F for fiscal year ended March 31, 2004 and 2005 amended 20-F for fiscal 2005 and our previous correspondence (file no. 0-30314)
We refer to your letter of December 20, 2005.
We regret the delay in our response since I was outside the country on vacation until January 12, 2006.
We give below our responses to your comments in the same order:
1. Our response letter dated September 9, 2005 has now been filed on January 12, 2006 under the accession no. 0001095435-06-000001.
2. We are confused here. We DID recognize compensation costs for a stock based award over the period in which the related services were rendered. Perhaps the following details will help explain:
Stock Option
Stock Compensation (in Canadian dollar)
Total
Total fair value-upon issuance
$5,265,240
$1,283,611
$6,548,851
Less: Recognized as expense for fiscal 2005 to the extent services provided
($4,120,088)
($695,834)
($4,815,922)*
Balance related to future services to rendered being deferred
$1,145,152
$587,776
$1,732,929**
* as per consolidated statement of operations
** Deferred stock based compensation on the balance sheet
Please contact the undersigned for any further information in the matter.
Sincerely,
/s/Kam Shah
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CORRESP 1 filename1.htm BONTAN CORPORATION INC BONTAN CORPORATION INC. 47 AVENUE ROAD, SUITE 200 TORONTO, ONTARIO, CANADA M5R 2G3 T: 416-929-1806 F: 416-361-6228 W: www.bontancorporation.com January 16, 2006 Jill S. Davis Branch Chief US Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549-7410 USA By fax sent to Jennifer Goeken – Division of Corporation Finance (also filed on EDGAR) Dear Jill S. Davis: RE: BONTAN CORPORATION INC. – Form 20-F for fiscal year ended March 31, 2004 and 2005 amended 20-F for fiscal 2005 and our previous correspondence (file no. 0-30314) We refer to your letter of December 20, 2005. We regret the delay in our response since I was outside the country on vacation until January 12, 2006. We give below our responses to your comments in the same order: 1. Our response letter dated September 9, 2005 has now been filed on January 12, 2006 under the accession no. 0001095435-06-000001. 2. We are confused here. We DID recognize compensation costs for a stock based award over the period in which the related services were rendered. Perhaps the following details will help explain: Stock Option Stock Compensation (in Canadian dollar) Total Total fair value-upon issuance $5,265,240 $1,283,611 $6,548,851 Less: Recognized as expense for fiscal 2005 to the extent services provided ($4,120,088) ($695,834) ($4,815,922)* Balance related to future services to rendered being deferred $1,145,152 $587,776 $1,732,929** * as per consolidated statement of operations ** Deferred stock based compensation on the balance sheet Please contact the undersigned for any further information in the matter. Sincerely, /s/Kam Shah Kam Shah Chief Executive and Financial Officer