SEC Comment Letter for STREAM COMMUNICATIONS NETWORK & MEDIA INC. (CIK 0001125670) — Oct 20, 2005
STREAM COMMUNICATIONS NETWORK & MEDIA INC. (CIK 0001125670)
Date: Oct. 20, 2005 · CIK: 0001125670 · Accession: 0000000000-05-053524
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File numbers found in text: 000-30942
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Mail Stop 3561
September 30, 2005
Casey Forward,
Chief Financial Officer
Suite 1020 - 400 Burrard Street
Vancouver, British Columbia, V6C 3A6
Re: Stream Communications Network and Media, Inc
Form 20-F for Fiscal Year Ended December 31, 2004
Filed May 2, 2005
Form 6-K for Fiscal Quarter Ended March 31, 2005
File No. 000-30942
Dear Mr. Forward:
Please address the following comments in future filings. If
you disagree, we will consider your explanation as to why our
comment
is inapplicable or a future revision is unnecessary. Please be as
detailed as necessary in your explanations. In some of our
comments,
we may ask you to provide us with 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 numbers
listed
at the end of this letter.
Form 20-F for the fiscal year ended December 31, 2004
Liquidity, Capital Resources and Subsequent Events, page 27
1. Please refer to prior comment #2. Revise to discuss your
assessment of the likelihood that your plans to continue as a
going
concern can be effectively implemented. Your discussion should
include the factors identified in your response letter. Refer to
Item 303(A)(1) of Regulation S-K.
Contractual Obligations, page 28
2. Please refer to prior comment #3. Revise to disclose your
rent
obligations together with contractual obligations as required by
Item
303(A)(5) of Regulation S-K.
Consolidated Statements of Operations and Deficit
3. Please refer to prior comment #8. Since the subtotal is not
expressly permitted under Canadian GAAP, delete this subtotal.
Note 12. Capital Stock
4. Please refer to prior comment # 11. Based on your response,
revise to delete your reference to "average."
* * * *
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please file your response via EDGAR. You may wish to provide us
with
marked copies of the amendment to expedite our review. Please
furnish a letter that keys your responses to our comments and
provides any requested information. Detailed letters greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your responses to our comments.
You may contact Nicole Holden, Staff Accountant, at (202)
551-
3374 or Dean Suehiro, Senior Staff Accountant, at (202) 551-3384
if
you have questions regarding comments on the financial statements
and
related matters. Please contact me at (202) 551-3810 with any
other
questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Forward
Stream Communications Network and Media, Inc
September 30, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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