SEC Comment Letter for VITA EQUITY INC (CIK 0001125918) — Jan 27, 2005
VITA EQUITY INC (CIK 0001125918)
Date: Jan. 27, 2005 · CIK: 0001125918 · Accession: 0000000000-05-004153
AI Filing Summary & Sentiment
File numbers found in text: 333-119147
Letter
January 25, 2005 VIA U.S. MAIL AND FACSIMILE Mr. Dwight Webb President and Chief Executive Officer Vita Equity, Inc. 837 West Hastings Street - Suite 314 Vancouver, British Columbia V6C 3N6 CANADA
Re: Vita Equity, Inc. Amendment No. 2 to Form SB-2 Filed on January 18, 2005 File No. 333-119147
Dear Mr. Webb:
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 us at the telephone numbers listed at the end of this letter.
Plan of Operations, page 26
1. We note your response to our prior comment 12. Please disclose the likelihood that you will be able to obtain funding from these sources to provide you with sufficient funds to meet your needs for the next twelve months. Also, please disclose whether you would be required to stop operating as a going concern if you are unable to decrease your marketing expenditures, increase your gross profit margin, and/or borrow sufficient funds.
* * * * * *
You may contact Robert Burnett, at (202) 942-1809, or Michael Moran, Accounting Branch Chief, at (202) 942-2823, if you have questions regarding comments on the financial statements and related matters. Please contact John Fieldsend, at (202) 824-5505, or Ellie Quarles, Special Counsel, at (202) 942-1859, or me at (202) 942- with any other questions.
Sincerely,
H. Christopher Owings
Assistant Director
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Mail Stop 0308
January 25, 2005
VIA U.S. MAIL AND FACSIMILE
Mr. Dwight Webb
President and Chief Executive Officer
Vita Equity, Inc.
837 West Hastings Street - Suite 314
Vancouver, British Columbia V6C 3N6
CANADA
Re: Vita Equity, Inc.
Amendment No. 2 to Form SB-2
Filed on January 18, 2005
File No. 333-119147
Dear Mr. Webb:
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 us at the telephone numbers
listed
at the end of this letter.
Plan of Operations, page 26
1. We note your response to our prior comment 12. Please disclose
the likelihood that you will be able to obtain funding from these
sources to provide you with sufficient funds to meet your needs
for
the next twelve months. Also, please disclose whether you would
be
required to stop operating as a going concern if you are unable to
decrease your marketing expenditures, increase your gross profit
margin, and/or borrow sufficient funds.
* * * * * *
You may contact Robert Burnett, at (202) 942-1809, or
Michael
Moran, Accounting Branch Chief, at (202) 942-2823, if you have
questions regarding comments on the financial statements and
related
matters. Please contact John Fieldsend, at (202) 824-5505, or
Ellie
Quarles, Special Counsel, at (202) 942-1859, or me at (202) 942-
1900
with any other questions.
Sincerely,
H. Christopher Owings
Assistant Director
cc: Mr. Doug Bolen
c/o Vita Equity, Inc.
837 West Hastings Street - Suite 314
Vancouver, British Columbia, V6C 3N6
CANADA
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Vita Equity, Inc.
January 25, 2005
Page 1
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