SEC Comment Letter for SPECTRAL CAPITAL Corp (FCCN) (CIK 0001131903) (FCCN) — Sep 12, 2008
SPECTRAL CAPITAL Corp (FCCN) (CIK 0001131903)
Date: Sept. 12, 2008 · CIK: 0001131903 · Accession: 0000000000-08-046031
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File numbers found in text: 000-50274
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Mail Stop 4561 September 11, 2008 Ms. Jenifer Osterwalder Chief Executive Officer FUSA Capital Corporation 1420 Fifth Avenue 22
nd Floor
Seattle, WA 98101
Re: FUSA Capital Corporation Form 10-KSB for Fiscal Year Ended December 31, 2007 Forms 10-Q for Fiscal Quarters Ended March 31, 2008 and June 30, 2008 File No. 000-50274
Dear Ms. Osterwalder:
We have reviewed the above-referenced f ilings and have the following comments.
Please note that we have limited our review to the matters addressed in the comments
below. If 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. Pl ease 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 raise additional comments.
Form 10-Q for Fiscal Quarter Ended June 30, 2008
Exhibit 31.1
1. We note that you filed your Principal Ex ecutive Officer and Principal Financial
Officer certification under Item 601(b)( 31) of Regulation S-K. Please amend
your filing and revise this certification to include the introductory language of paragraph 4 and the language of paragra ph 4(b) of Item 601(b)(31) of Regulation
S-K. Similar concerns apply to your Form 10-Q for the fiscal quarter ended
March 31, 2008.
* * * * * * *
Ms. Jenifer Osterwalder
FUSA Capital Corporation September 11, 2008 Page 2
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please submit all correspondence and supplemental materials
on EDGAR as required by Rule 101 of Regulation S-T. If you amend your filing(s), you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter that keys your response to our comment and provides any
requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comm ents after reviewing any amendment and
your response to our comment.
You may contact Mark Sh annon, Staff Accountant, at (202) 551-3299 or me at
(202) 551-3408 if you have any questions regarding the above comment.
S i n c e r e l y , C h r i s t i n e D a v i s
Assistant Chief Accountant