SEC Comment Letter for Phinder Technologies Inc (CIK 0001136386) — Oct 13, 2005
Phinder Technologies Inc (CIK 0001136386)
Date: Oct. 13, 2005 · CIK: 0001136386 · Accession: 0000000000-05-052469
AI Filing Summary & Sentiment
File numbers found in text: 000-32559
Referenced dates: August 23, 2005
Letter
October 13, 2005 Mail Stop 4561 John A. van Arem Chief Executive Officer Digital Rooster.Com LTD. 366 Bay Street, 12th Floor Toronto, Ontario, Canada M5H 4B2
Re: Digital Rooster.Com LTD. Form 20-F/A for the Fiscal Year Ended March 31, 2004 File No. 000-32559 Filed October 7, 2004 Form 6-K for the Quarterly Period Ended June 30, 2004 File No. 000-32559 Filed October 7, 2004 Form 6-K for the Quarterly Period Ended September 30, 2004 File No. 000-32559 Filed November 15, 2004
Dear Mr. van Arem:
We have reviewed your response letter dated August 23, 2005 and have the following additional comments. If you disagree with our comments, we will consider your explanation as to why our comments are not applicable. Please be as detailed as necessary in your explanation.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 20-F for the year ended March 31, 2004
Financial Statements
General
1. Explain to us where you disclosed details of your restatement in the notes to your restated financial statements or revise to include this information. Additionally, revise to label each year restated as such on the face of financial statements.
Auditors` Report, page 1
2. As your financial statements were restated subsequent to the date of your independent auditors` report, it is unclear to us if the restatement was audited by your auditors. If so, tell us how your auditors modified their report to indicate that they had audited the restatement or revise accordingly.
Gain on dilution of investment in subsidiary, page 15
3. We have considered your response to comment 6. It is still unclear to us how you have accounted for the issuance of treasury shares of Avrada, Inc. and why the transaction results in a gain in your income statement. Tell us, in detail, the nature of the transaction, how you have accounted for it, and your accounting basis for doing so.
Please respond to the comments included in this letter within ten business days. Please file your response on EDGAR. If you have any questions, you may contact Robert Telewicz at (202) 551-3438 or me at (202) 551-3413.
Sincerely,
Cicely Luckey
Accounting Branch Chief
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Show Raw Text
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<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
October 13, 2005
Mail Stop 4561
John A. van Arem
Chief Executive Officer
Digital Rooster.Com LTD.
366 Bay Street, 12th Floor
Toronto, Ontario, Canada M5H 4B2
Re: Digital Rooster.Com LTD.
Form 20-F/A for the Fiscal Year Ended
March 31, 2004
File No. 000-32559
Filed October 7, 2004
Form 6-K for the Quarterly Period Ended
June 30, 2004
File No. 000-32559
Filed October 7, 2004
Form 6-K for the Quarterly Period Ended
September 30, 2004
File No. 000-32559
Filed November 15, 2004
Dear Mr. van Arem:
We have reviewed your response letter dated August 23, 2005
and
have the following additional comments. If you disagree with our
comments, we will consider your explanation as to why our comments
are not applicable. Please be as detailed as necessary in your
explanation.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 20-F for the year ended March 31, 2004
Financial Statements
General
1. Explain to us where you disclosed details of your restatement
in
the notes to your restated financial statements or revise to
include
this information. Additionally, revise to label each year
restated
as such on the face of financial statements.
Auditors` Report, page 1
2. As your financial statements were restated subsequent to the
date
of your independent auditors` report, it is unclear to us if the
restatement was audited by your auditors. If so, tell us how your
auditors modified their report to indicate that they had audited
the
restatement or revise accordingly.
Gain on dilution of investment in subsidiary, page 15
3. We have considered your response to comment 6. It is still
unclear to us how you have accounted for the issuance of treasury
shares of Avrada, Inc. and why the transaction results in a gain
in
your income statement. Tell us, in detail, the nature of the
transaction, how you have accounted for it, and your accounting
basis
for doing so.
Please respond to the comments included in this letter
within
ten business days. Please file your response on EDGAR. If you
have
any questions, you may contact Robert Telewicz at (202) 551-3438
or
me at (202) 551-3413.
Sincerely,
Cicely Luckey
Accounting Branch Chief
??
??
??
??
John van Arem
Digital Rooster.com LTD.
October 13, 2005
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</TEXT>
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