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SEC Comment Letter for NAVITONE TECHNOLOGIES INC (CIK 0001114302) — Nov 19, 2004

NAVITONE TECHNOLOGIES INC (CIK 0001114302)
Date: Nov. 19, 2004 · CIK: 0001114302 · Accession: 0000000000-04-037369

AI Filing Summary & Sentiment

Date
November 19, 2004
Author
Andrew Mew
Form
UPLOAD
Company
NAVITONE TECHNOLOGIES INC (CIK 0001114302)

Letter

Mail Stop 0409 VIA U.S. MAIL AND FAX (702) 314-2811 Mr. Herb Sider President World Wide Web, Inc. 4850 W. Flamingo Rd. #23 Las Vegas, NV 89103

Re: World Wide Web, Inc., Form 8-K filed November 12, 2004

Dear Mr. Sider:

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call me at the telephone number listed at the end of this letter.

1. Please amend the report to state whether the former accountant resigned, declined to stand for re-election or was dismissed, and the specific date, as required by Item 304(a)(1)(i) of Regulation S-K. It is not sufficient to state that the company was terminated, as that wording is unclear to a reader.

2. Please amend the report to clarify your statement (a)(iv) and (v) of Item 4.01 whether the periods cover the registrant`s two most recent fiscal years and any subsequent interim period preceding such resignation, declination or dismissal on the subject matter of disagreements and reportable events.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 comment, 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 filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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.

Please provide the supplemental information requested above within 10 business days from the date of this letter. The supplemental information should be filed as correspondence on EDGAR. The amendment requested above should be filed as promptly as possible and should be reviewed by the newly engaged accountants before filing with the Commission.

You may reach me at (202) 942-2913 with any questions.

Sincerely,
Andrew Mew
Staff Accountant

Show Raw Text
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<DESCRIPTION>FORM 8-K ITEM 4 DTD 11/12/04 MEW
<TEXT>

					November 19, 2004

Mail Stop 0409

VIA U.S. MAIL AND FAX (702) 314-2811

Mr. Herb Sider
President
World Wide Web, Inc.
4850 W. Flamingo Rd. #23
Las Vegas, NV  89103

Re:	World Wide Web, Inc., Form 8-K filed November 12, 2004

Dear Mr. Sider:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation
as to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other aspect
of our review.  Feel free to call me at the telephone number listed
at the end of this letter.

1. Please amend the report to state whether the former accountant
resigned, declined to stand for re-election or was dismissed, and the
specific date, as required by Item 304(a)(1)(i) of Regulation S-K.
It is not sufficient to state that the company was terminated, as
that wording is unclear to a reader.

2. Please amend the report to clarify your statement (a)(iv) and (v)
of Item 4.01 whether the periods cover the registrant`s two most
recent fiscal years and any subsequent interim period preceding such
resignation, declination or dismissal on the subject matter of
disagreements and reportable events.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  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 comment, 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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

Please provide the supplemental information requested above within 10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The
amendment requested above should be filed as promptly as possible and
should be reviewed by the newly engaged accountants before filing
with the Commission.

You may reach me at (202) 942-2913 with any questions.

						Sincerely,

						Andrew Mew
						Staff Accountant

World Wide Web, Inc.
November 19, 2004

Page 2

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</DOCUMENT>