SEC Comment Letter for MILL CREEK RESEARCH INC (CIK 0001116773) — Feb 23, 2005
MILL CREEK RESEARCH INC (CIK 0001116773)
Date: Feb. 23, 2005 · CIK: 0001116773 · Accession: 0000000000-05-008739
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
February 23, 2005
Ms. Rita Thomas
President, Director
Mill Creek Research, Inc.
1007 N. Cactus Trail
Seymour, Texas 76380
RE: Form 8-K/A Item 4.01 filed February 23, 2005
File # 0-30875
Dear Ms. Thomas:
We have reviewed your filing and have the following comments.
Where
indicated, we think you should revise your documents 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 us at the telephone number
listed
at the end of this letter.
1. You currently disclose that "none of the reports of Banker &
Co.
on the financial statements of the Company contained any adverse
opinion or disclaimer of opinion, or was qualified or modified as
to
uncertainty, audit scope, or accounting principles, nor have there
been at any time, disagreements between the Company and Banker &
Co.
on any matter of accounting principles or practices, financial
statement disclosure or auditing scope or procedure." Please
amend
your Form 8-K to disclose this information related to the
principal
accountant`s report on the financial statements for either of the
past two years, instead of stating "none of the reports." See
Item
304(a)(1)(ii) of Regulation S-B.
2. To the extent that you make changes to the Form 8-K to comply
with
our comments, please obtain and file an updated Exhibit 16 letter
from the former accountants stating whether the accountant agrees
with the statements made in your revised Form 8-K.
*****
Please file your supplemental response via EDGAR in response to
these
comments within 5 business days of the date of this letter.
Please
note that if you require longer than 5 business days to respond,
you
should contact the staff immediately to request additional time.
You
may wish to provide us with marked copies of each amended filing
to
expedite our review. Direct any questions regarding the above to
the
undersigned at (202) 824-5685.
Sincerely,
Jeffrey Gordon
Staff Accountant
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Ms. Thomas
February 23, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510
DIVISION OF
CORPORATION FINANCE
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