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SEC Company Response from IKONA GEAR INTERNATIONAL INC (CIK 0001130809) — Aug 24, 2005

IKONA GEAR INTERNATIONAL INC (CIK 0001130809)
Date: Aug. 24, 2005 · CIK: 0001130809 · Accession: 0001011034-05-000165

AI Filing Summary & Sentiment

File numbers found in text: 333-126523

Referenced dates: July 22, 2005

Date
August 24, 2005
Author
/s/ Clifford L. Neuman
Form
CORRESP
Company
IKONA GEAR INTERNATIONAL INC (CIK 0001130809)

Letter

VIA EDGAR AND FACSIMILE United States Securities and Exchange Commission Re: Ikona Gear International, Inc. Registration Statement on Form SB-2 File No. 333-126523

Dear Mr. Sanderson:

On behalf of Ikona Gear International, Inc. (the "Company"), please be advised that the Company has reviewed your comments dated July 22, 2005 in connection with the above referenced filing.

In response to Comment No. 2, we have inquired of the selling security holders who are not natural persons and who are not a reporting company under the Exchange Act to identify the person or persons who exercise the sole or shared voting and investment power with respect to the securities. All of those selling security holders responded by informing us that they are Swiss banking institutions and that under Swiss banking law they are not permitted to disclose the identity of their clients.

Would you please advise us how you would like us to respond to this comment and what, if any, disclosure you would like us to make in the Registration Statement, in light of the above information

Sincerely,
/s/ Clifford L. Neuman

Show Raw Text
CORRESP
1
filename1.htm

CLIFFORD L. NEUMAN, P.C.

Attorney at Law

TEMPLE-BOWRON HOUSE

1507 PINE STREET

BOULDER, COLORADO 80302

Telephone: (303) 449-2100

Facsimile: (303) 449-1045

E-mail:  clneuman@neuman.com

August 24, 2005

VIA EDGAR AND FACSIMILE

Errol Sanderson, Staff Attorney

United States Securities and Exchange Commission

450 Fifth Street N.W.

Mail Stop 70-10

Washington, D.C.  20549

Re:

Ikona Gear International, Inc.

Registration Statement on Form SB-2

File No. 333-126523

Dear Mr. Sanderson:

          On behalf of Ikona Gear International, Inc. (the "Company"), please be advised that the Company has reviewed your comments dated July 22, 2005 in connection with the above referenced filing.

          In response to Comment No. 2, we have inquired of the selling security holders who are not natural persons and who are not a reporting company under the Exchange Act to identify the person or persons who exercise the sole or shared voting and investment power with respect to the securities. All of those selling security holders responded by informing us that they are Swiss banking institutions and that under Swiss banking law they are not permitted to disclose the identity of their clients.

          Would you please advise us how you would like us to respond to this comment and what, if any, disclosure you would like us to make in the Registration Statement,  in light of the above information

Sincerely,

/s/ Clifford L. Neuman

Clifford L. Neuman

CLN: nn