SEC Comment Letter for Thomas Equipment, Inc. (CIK 0001122380) — Dec 29, 2004
Thomas Equipment, Inc. (CIK 0001122380)
Date: Dec. 29, 2004 · CIK: 0001122380 · Accession: 0000000000-04-042342
AI Filing Summary & Sentiment
File numbers found in text: 333-44586
Letter
December 29, 2004 Via U.S. Mail Clifford Rhee President Thomas Equipment, Inc. f/k/a Maxim Mortgage Corp. 1818 North Farwell Avenue Milwaukee, WI 53202
Re: Thomas Equipment, Inc., f/k/a Maxim Mortgage Corp. Form 8-K, Item 4.01, filed November 15, 2004 Form 8-K/A Item 4.01, filed December 10, 2004 File No. 333-44586
Dear Mr. Rhee:
We have reviewed your filing and, as we discussed in our telephone conversation of December 17, 2004, we have the following 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 numbers listed at the end of this letter.
Form 8-K/A filed on December 10, 2004 1. We note that your name has changed to Thomas Equipment, Inc. Within the EDGAR system, however, you continue to be identified as Maxim Mortgage Corporation. Your company information should be updated through the EDGAR website as soon as possible. For assistance in updating company information you may contact Filer Support at (202) 942-8900.
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.
As previously requested, in connection with responding to our comments, 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 comment 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 should be filed as promptly as possible. Please note that if you require longer than 10 business days to respond, you should contact the staff immediately to request additional time. Any questions regarding the above should be directed to me at (202) 942-1987, or in my absence, to Robert Benton at (202) 942-1811.
Sincerely,
Tamara Tangen
Staff Accountant
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>upload.txt
<DESCRIPTION>ITEM 4.01 8-K/A ACCT COMMENT LETTER - TANGEN
<TEXT>
Mail Stop 04-06
December 29, 2004
Via U.S. Mail
Clifford Rhee
President
Thomas Equipment, Inc.
f/k/a Maxim Mortgage Corp.
1818 North Farwell Avenue
Milwaukee, WI 53202
Re: Thomas Equipment, Inc., f/k/a Maxim Mortgage Corp.
Form 8-K, Item 4.01, filed November 15, 2004
Form 8-K/A Item 4.01, filed December 10, 2004
File No. 333-44586
Dear Mr. Rhee:
We have reviewed your filing and, as we discussed in our
telephone conversation of December 17, 2004, we have the following
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 numbers
listed
at the end of this letter.
Form 8-K/A filed on December 10, 2004
1. We note that your name has changed to Thomas Equipment, Inc.
Within the EDGAR system, however, you continue to be identified as
Maxim Mortgage Corporation. Your company information should be
updated through the EDGAR website as soon as possible. For
assistance
in updating company information you may contact Filer Support at
(202) 942-8900.
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.
As previously requested, in connection with responding to
our
comments, 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 comment 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 should be filed as promptly as possible.
Please note that if you require longer than 10 business days to
respond, you should contact the staff immediately to request
additional time. Any questions regarding the above should be
directed to me at (202) 942-1987, or in my absence, to Robert
Benton
at (202) 942-1811.
Sincerely,
Tamara Tangen
Staff Accountant
??
??
??
??
Thomas Equipment, Inc., f/k/a Maxim Mortgage Corp.
December 29, 2004
Page 2
</TEXT>
</DOCUMENT>