SEC Comment Letter for Trinsic, Inc. (CIK 0001096509) — Aug 12, 2005
Trinsic, Inc. (CIK 0001096509)
Date: Aug. 12, 2005 · CIK: 0001096509 · Accession: 0000000000-05-041901
AI Filing Summary & Sentiment
File numbers found in text: 000-28467
Letter
Mail Stop 3561 August 12, 2005 Horace J. Davis, III Trinsic, Inc. 601 South Harbour Island Boulevard, Suite 220 Tampa, Florida 33602
RE: Trinsic, Inc. Preliminary Proxy Statement on Schedule 14A File No. 000-28467 Filed August 5, 2005
Dear Mr. Davis:
We limited our review of your filing to matters relating to the outstanding accounting comments issued in connection with our review of your Form 10-K for the fiscal year ended December 31, 2004 as well as certain portions of the proxy statement`s disclosure.
Please respond to our comments, which were issued through our phone conversation with your counsel on August 12, 2005, by filing a revised preliminary proxy statement. When you respond, please furnish a cover letter that keys your responses to our comments. If you believe that compliance with our comments is not appropriate, please provide the basis for your view in your response letter, which you should file electronically on EDGAR under the tag "CORRESP." Please also note the location of any material changes made in the materials for reasons other than in response to specific staff comments. Also, note the requirements of Rule 14a-6(h) of Regulation 14A and Rule 310 of Regulation S-T.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the disclosure in the filing;
* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
If you have any questions, please call Ted Yu at (202) 551- or me at (202) 551-3833.
Sincerely,
Michele M. Anderson
Legal Branch Chief
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 3561
August 12, 2005
Horace J. Davis, III
Trinsic, Inc.
601 South Harbour Island Boulevard, Suite 220
Tampa, Florida 33602
RE: Trinsic, Inc.
Preliminary Proxy Statement on Schedule 14A
File No. 000-28467
Filed August 5, 2005
Dear Mr. Davis:
We limited our review of your filing to matters relating to
the
outstanding accounting comments issued in connection with our
review
of your Form 10-K for the fiscal year ended December 31, 2004 as
well
as certain portions of the proxy statement`s disclosure.
Please respond to our comments, which were issued through
our
phone conversation with your counsel on August 12, 2005, by filing
a
revised preliminary proxy statement. When you respond, please
furnish a cover letter that keys your responses to our comments.
If
you believe that compliance with our comments is not appropriate,
please provide the basis for your view in your response letter,
which
you should file electronically on EDGAR under the tag "CORRESP."
Please also note the location of any material changes made in the
materials for reasons other than in response to specific staff
comments. Also, note the requirements of Rule 14a-6(h) of
Regulation
14A and Rule 310 of Regulation S-T.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
If you have any questions, please call Ted Yu at (202) 551-
3372
or me at (202) 551-3833.
Sincerely,
Michele M. Anderson
Legal Branch Chief
cc: Gary A. Brooks
Cahill Gordon & Reindel
??
??
??
??
Horace J. Davis, III
Trinsic, Inc.
August 12, 2005
Page 2
</TEXT>
</DOCUMENT>