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SEC Comment Letter for INNOFONE COM INC (CIK 0001100364) — Sep 22, 2005

INNOFONE COM INC (CIK 0001100364)
Date: Sept. 22, 2005 · CIK: 0001100364 · Accession: 0000000000-05-049138

AI Filing Summary & Sentiment

File numbers found in text: 000-31949

Referenced dates: September 6, 2005

Date
September 22, 2005
Author
Linda van Doorn
Form
UPLOAD
Company
INNOFONE COM INC (CIK 0001100364)

Letter

Mail Stop 4561 VIA U.S. MAIL AND FAX (301) 230-9675 Mr. Frederic Richardson President Innofone.Com, Inc. 3470 Olney-Laytonsville Road, Suite 118 Olney, MD 20832

Re: Innofone.Com, Inc. Form 10-KSB for the year ended June 30, 2004 Filed October 13, 2004 File No. 000-31949

Dear Mr. Richardson:

We have reviewed your response letter dated September 6, and have the following additional comments. Feel free to call us at the telephone numbers listed at the end of this letter.

1. We read your response to comment 4 and your revised statement of operations included in your Form 10-KSB/A filed on September 6, 2005. In future filings, please remove any reference to these items as extraordinary since these items do not meet the definition of extraordinary in paragraph 26 of APB 30. Notwithstanding the above, further clarify to us how you determined that this debt forgiveness was not a capital contribution. Refer to paragraph 20 of APB 26.

2. Please revise your certification filed as Exhibit 31.1 to reflect the language exactly as set forth in Item 601(b)(31) of Regulation S- K. Please also make conforming revisions to all subsequent Forms 10- QSB.

3. We read your Form 8-K filed on August 19, 2005 with respect to your acquisition IPv6 Summit, Inc. Please tell us how you plan to account for this acquisition in your financial statements.

* * * *

You may contact Josh Forgione, at (202) 551-3431, or me, at (202) 551-3498, 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,
Linda van Doorn
Senior Assistant Chief Accountant

Show Raw Text
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<TEXT>

      September 22, 2005

Mail Stop 4561

VIA U.S. MAIL AND FAX (301) 230-9675

Mr. Frederic Richardson
President
Innofone.Com, Inc.
3470 Olney-Laytonsville Road, Suite 118
Olney, MD  20832

      Re:	Innofone.Com, Inc.
      Form 10-KSB for the year ended June 30, 2004
      Filed October 13, 2004
      File No. 000-31949

Dear Mr. Richardson:

      We have reviewed your response letter dated September 6,
2005
and have the following additional comments.  Feel free to call us
at
the telephone numbers listed at the end of this letter.

1. We read your response to comment 4 and your revised statement
of
operations included in your Form 10-KSB/A filed on September 6,
2005.
In future filings, please remove any reference to these items as
extraordinary since these items do not meet the definition of
extraordinary in paragraph 26 of APB 30.  Notwithstanding the
above,
further clarify to us how you determined that this debt
forgiveness
was not a capital contribution.  Refer to paragraph 20 of APB 26.

2. Please revise your certification filed as Exhibit 31.1 to
reflect
the language exactly as set forth in Item 601(b)(31) of Regulation
S-
K.  Please also make conforming revisions to all subsequent Forms
10-
QSB.

3. We read your Form 8-K filed on August 19, 2005 with respect to
your acquisition IPv6 Summit, Inc.  Please tell us how you plan to
account for this acquisition in your financial statements.

*  *  *  *

      You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3498, 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,

      Linda van Doorn
      Senior Assistant Chief Accountant

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Mr. Frederic Richardson
Innofone.Com, Inc.
September 22, 2005
Page 1

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