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SEC Comment Letter for UNITY WIRELESS CORP (CIK 0001100451) — Apr 6, 2005

UNITY WIRELESS CORP (CIK 0001100451)
Date: April 6, 2005 · CIK: 0001100451 · Accession: 0000000000-05-016478

AI Filing Summary & Sentiment

File numbers found in text: 333-123623

Date
April 5, 2005
Author
Larry Spirgel
Form
UPLOAD
Company
UNITY WIRELESS CORP (CIK 0001100451)

Letter

April 5, 2005 Mail Stop 0407 Dallas Pretty Chief Financial Officer Unity Wireless Corporation 7438 Fraser Park Drive Burnaby, British Columbia, Canada V5J 5B9

RE: Unity Wireless Corporation Registration Statement on Form SB-2 File No. 333-123623 Filed March 28, 2005

Dear Mr. Pretty:

This is to advise you that no review of the above registration statement has been or will be made. All persons who are by statute responsible for the adequacy and accuracy of the registration statement are urged to be certain that all information required under the Securities Act of 1933 has been included.

You are also reminded to consider applicable requirements regarding distribution of the preliminary prospectuses.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in your filing to be certain that they have provided all information investors require for an informed 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 disclosure they have made.

In the event the company requests acceleration of the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:

* should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

* the company may not assert the declaration of effectiveness 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 connection with your filing.

We will consider a written request for acceleration of the effective date of the registration statement as a confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement. We will act on the request and, pursuant to delegated authority, grant acceleration of the effective date.

If you have any questions, please call Ted Yu at (202) 824- 5684.

Sincerely,
Larry Spirgel
Assistant Director

Show Raw Text
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<TEXT>

      April 5, 2005

Mail Stop 0407

Dallas Pretty
Chief Financial Officer
Unity Wireless Corporation
7438 Fraser Park Drive
Burnaby, British Columbia, Canada V5J 5B9

	RE:	Unity Wireless Corporation
		Registration Statement on Form SB-2
		File No. 333-123623
		Filed March 28, 2005

Dear Mr. Pretty:

	This is to advise you that no review of the above
registration
statement has been or will be made.  All persons who are by
statute
responsible for the adequacy and accuracy of the registration
statement are urged to be certain that all information required
under
the Securities Act of 1933 has been included.

	You are also reminded to consider applicable requirements
regarding distribution of the preliminary prospectuses.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in your filing to be certain that they
have provided all information investors require for an informed
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 disclosure they have made.

	In the event the company requests acceleration of the
effective
date of the pending registration statement, it should furnish a
letter, at the time of such request, acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert the declaration of effectiveness 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 connection with your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	If you have any questions, please call Ted Yu at (202) 824-
5684.

							Sincerely,

							Larry Spirgel
Assistant Director

</TEXT>
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