SEC Company Response from Charlie's Holdings, Inc. (CHUC) (CIK 0001134765) (CHUC) — Oct 25, 2004
Charlie's Holdings, Inc. (CHUC) (CIK 0001134765)
Date: Oct. 25, 2004 · CIK: 0001134765 · Accession: 0001104659-04-031643
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CORRESP 1 a04-11752_2corresp.htm CORRESP 480 S. Holly Street . Suite 5 Denver, Colorado 80246 Main: 303-316-8577 Toll Free: 800-313-2234 Fax: 303-316-9004 www.v3s.com October 25, 2004 VIA EDGAR Sasha Parikh, Staff Accountant United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: VitaCube Systems Holdings, Inc. SEC File No. 0-50875 Form 8-K filed October 12, 2004 Our File No. 5037.02 Dear Ms. Parik: We have reviewed your comment letter, dated October 18, 2004. Unlike Regulation S-K, Item 304(a)(1)(iv) of Regulation S-B does not specify the period in which to address whether the registrant had a disagreement with its former accountant. In light of this difference and the fact that we are a Regulation S-B filer, in further discussions with the staff, the staff has agreed that we do not need to amend our Form 8-K. Thus no amendment will be filed. In connection with our response, the Company acknowledges the following: The Company is responsible for the adequacy and accuracy of the disclosure in the filings; staff comments or changes to disclosure in response to staff comments in the filing reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. If you have any questions or require any additional information, please contact Jane M. Harm at (303) 753 - 9000. Very truly yours, VITACUBE SYSTEMS HOLDINGS, INC. By: /s/ Sanford D. Greenberg Sanford D. Greenberg, Chief Executive Officer