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SEC Company Response from IKONA GEAR INTERNATIONAL INC (CIK 0001130809) — Sep 27, 2005

IKONA GEAR INTERNATIONAL INC (CIK 0001130809)
Date: Sept. 27, 2005 · CIK: 0001130809 · Accession: 0001011034-05-000189

AI Filing Summary & Sentiment

File numbers found in text: 333-126523

Date
September 27, 2005
Author
/s/ Clifford L. Neuman
Form
CORRESP
Company
IKONA GEAR INTERNATIONAL INC (CIK 0001130809)

Letter

VIA EDGAR AND OVERNIGHT DELIVERY United States Securities and Exchange Commission Re: Ikona Gear International, Inc. Pre-Effective Amendment No. 1 to 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, on this date, electronically filed by EDGAR with the Commission its pre-effective Amendment No. 1 to Form SB-2 Registration Statement.

I am enclosing herewith for your convenience two sets of the Amendment, each set consisting of one redlined and one clean Registration Statement.

To expedite your review, please accept the following in response to the comments of the Commission dated July 22, 2005:

Comment No. 1.

Supplementally, please be advised that no Selling Securityholder is a broker-dealer or an affiliate of a broker-dealer.

Comment No. 2.

Revised as requested. See page 43.

Comment No. 3.

We have revised the Registration Statement as requested. See page 44.

Comment No. 4.

Revised as requested. See page 44.

Please let me know if you have further comments or questions.

Sincerely,
/s/ Clifford L. Neuman

Show Raw Text
CORRESP
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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

September 27, 2005

VIA EDGAR AND OVERNIGHT DELIVERY

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.

Pre-Effective Amendment No. 1 to 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, on this date, electronically filed by EDGAR with the Commission its pre-effective Amendment No. 1 to Form SB-2 Registration Statement.

          I am enclosing herewith for your convenience two sets of the Amendment, each set consisting of one redlined and one clean Registration Statement.

          To expedite your review, please accept the following in response to the comments of the Commission dated July 22, 2005:

Comment No. 1.

Supplementally, please be advised that no Selling Securityholder is a broker-dealer or an affiliate of a broker-dealer.

Comment No. 2.

Revised as requested.  See page 43.

Comment No. 3.

We have revised the Registration Statement as requested.  See page 44.

Comment No. 4.

Revised as requested.  See page 44.

          Please let me know if you have further comments or questions.

Sincerely,

/s/ Clifford L. Neuman

Clifford L. Neuman

cc:       Raymond Polman

CLN: map