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SEC Comment Letter for QUANTUM MRI, INC. (CIK 0001123844) — Nov 28, 2005

QUANTUM MRI, INC. (CIK 0001123844)
Date: Nov. 28, 2005 · CIK: 0001123844 · Accession: 0000000000-05-059665

AI Filing Summary & Sentiment

File numbers found in text: 000-31679

Date
November 28, 2005
Author
President
Form
UPLOAD
Company
QUANTUM MRI, INC. (CIK 0001123844)

Letter

MAIL STOP 3561 November 28, 2005 Mr. Kelly Fielder President Travelshorts.com, Inc. 4750 Paton St. Vancouver, BC Canada V6L 2J1

Re: Travelshorts.com, Inc. Item 4.01 Form 8-K/A Filed November 22, 2005 File No. 000-31679

Dear Mr. Fielder:

We have reviewed your filing and have the following comments. Where indicated, we think you should re vise 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 deta iled as necessary in your explanation. In some of our comments, we may ask you to provi de us with more information so we may better understand your disclosure. After re viewing this information, we may raise additional comments.

Please understand that the purpose of our re view 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 any other aspect of our review. Feel free to call me at the telephone number listed at the e nd of this letter.

Form 8-K/A filed November 22, 2005

1. We reviewed your amended filing and noted several disclosures were removed. Please amend your filing to include disclosures required by Items 304(a)(1)(iv)(D), 304(a)(1)(iv)(E) a nd 304(a)(2) of Regulation S-B.

As appropriate, please amend your filing and respond to these comments within five business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendm ent to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed co ver letters greatly faci litate our review.

Kelly Fie lder Travelshorts.com , Inc. November 28, 2005 Page 2

Please understand that we may have addi tional comments after reviewing your amendment and responses to our comments.

We urge all persons who are responsi ble for the accuracy an d adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating 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 comments, please provide, in writing, a statement from the registrant acknowledging that: • the registrant is responsible for the adequacy and accuracy of the disclosure in the filing; • staff comments or changes to disclosu re in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and • the registrant may not assert st aff comments as a defense in any proceeding initiated by the Commissi on or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.

If you have any questions, please call me at (202) 551-3390

S i n c e r e l y ,

B r i a n K . B h a n d a r i S t a f f A c c o u n t a n t

Show Raw Text
MAIL STOP 3561
November 28, 2005

Mr. Kelly Fielder
President
Travelshorts.com, Inc.
4750 Paton St.
Vancouver, BC Canada V6L 2J1

Re: Travelshorts.com, Inc.
 Item 4.01 Form 8-K/A
Filed November 22, 2005
 File No. 000-31679

Dear Mr. Fielder:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise 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 deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with more information so we may
better understand your disclosure.  After re viewing this information, we may raise
additional comments.

 Please understand that the purpose of our re view 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 any other aspect of our
review.  Feel free to call me at the telephone number listed at the e nd of this letter.

Form 8-K/A filed November 22, 2005

1. We reviewed your amended filing and noted several disclosures were removed.
Please amend your filing to include disclosures required by Items 304(a)(1)(iv)(D),
304(a)(1)(iv)(E) a nd 304(a)(2) of Regulation S-B.

 As appropriate, please amend your filing and respond to these comments within
five business days or tell us when you will provide us with a response.  You may wish to provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.

Kelly Fie lder
Travelshorts.com , Inc.
November 28, 2005
Page 2

Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 comments, please provide, in writing, a
statement from the registrant acknowledging that:
• the registrant is responsible for the adequacy and accuracy of the
disclosure in the filing;
• staff comments or changes to disclosu re in response to staff comments
do not foreclose the Commission from taking any action with respect to
the filing; and
• the registrant may not assert st aff comments as a defense in any
proceeding initiated by the Commissi on or any person under the federal
securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 If you have any questions, please call me at (202) 551-3390

       S i n c e r e l y ,

       B r i a n  K .  B h a n d a r i
       S t a f f  A c c o u n t a n t