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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

AI Filing Summary & Sentiment

Date
August 29, 2005
Author
Chief Operating Officer
Form
CORRESP
Company
EP GLOBAL COMMUNICATIONS INC (CIK 0001113947)

Letter

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

<PAGE> 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

Show Raw Text
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<TEXT>
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

<PAGE>
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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