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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

AI Filing Summary & Sentiment

Date
October 25, 2004
Author
VITACUBE SYSTEMS HOLDINGS
Form
CORRESP
Company
Charlie's Holdings, Inc. (CHUC) (CIK 0001134765)

Letter

VIA EDGAR United States Securities and Exchange Commission 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.

Show Raw Text
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