SEC Company Response from EP GLOBAL COMMUNICATIONS INC (CIK 0001113947) — Aug 29, 2005
EP GLOBAL COMMUNICATIONS INC (CIK 0001113947)
Date: Aug. 29, 2005 · CIK: 0001113947 · Accession: 0001065943-05-000034
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EP Exceptional Parent
551 Main Street
Johnstown, PA 15901
Toll Free: (800) 372-7368
Tel: (814) 361-3860
Fax: (814) 361-3861
WWW.EPARENT.COM
August 29, 2005
Mr. David R. Humphrey
Branch Chief - Accountant
Securities and Exchange Commission
Washington, DC 20549-0305
RE: EP Global Communications, Inc.
Item 4.02 Form 8-K
Filed August 9, 2005
File No. 0-30797
Dear Mr. Humphrey,
EP Global Communications, Inc. ("Company") has received a comment letter from
the SEC under date of August 15, 2005. As requested in such letter, the
Company herewith provides responses to the questions raised by staff. For
convenience, the matters are listed below, followed by the Company's
responses.
Item 4.02 Form 8-K
1. Expand the disclosure to indicate that your board of directors
concluded that the financial statements for the year ended December 31, 2004 as
issued in your annual report on Form 10-KSB should no longer be relied upon.
See Item 4.02(a)(1) of Form 8-K.
2. Also, expand the disclosure to indicate whether an audit committee
or the board of directors or authorized officer or officers discussed the
matter with your registered independent accountants. See Item 4.02(a)(3) of
Form 8-K.
The Company will file an amended Form 8-K on approximately August
29, 2005. The amendment will contain the following disclosure:
ITEM 4.02. NON-RELIANCE ON PREVIOUSLY ISSUED FINANCIAL
STATEMENTS OR A RELATED AUDIT REPORT OR COMPLETED
INTERIM REVIEW
On August 3, 2005, as a result of a
routine regulatory review by the
Securities and Exchange Commission
and,after discussion between the
Company's audit committee of the
board of directors and the
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MR. DAVID R. HUMPHREY, SECURITIES AND EXCHANGE COMMISSION,
AUGUST 26, 2005 PAGE 2
Company's registered independent accountants, the
Company's board of directors concluded that the
financial statements for the year ended December 31,
2004 as issued in the Registrant's annual report on Form
10-KSB required restatement and could no longer be
relied upon because of an error in recognizing income
associated with the formation of Informedx LLC. The
error was corrected by recognizing funds received from
Informedx LLC as additional minority interest and an
amendment was filed to the Company's Form 10-KSB in
accordance with this change.
* * * * *
In connection with this response to the matters enumerated above, the Company
acknowledges 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.
* * * * *
Should there be any other questions or comments, please contact me.
Sincerely
/s/ Robert J. Salluzzo
Robert J. Salluzzo
Chief Operating Officer
C. Ms. Beverly Singleton
Division of Corporate Finance
Via Facsimile Copy - 202 772 9202
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