SEC Comment Letter for MEDSTRONG INTERNATIONAL CORP (CIK 0001136711) — Jul 27, 2005
MEDSTRONG INTERNATIONAL CORP (CIK 0001136711)
Date: July 27, 2005 · CIK: 0001136711 · Accession: 0000000000-05-038552
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Mail Stop 4561
July 27, 2005
Ms. Jeanine Folz
Chief Executive and Principal Financial Officer
Medstrong International Corporation
350 Bedford Street, Suite 203
Stamford, CT 06901
RE: Medstrong International Corporation
Form 8-K
Filed July 26, 2005
File No. 0-33035
Dear Ms. Folz:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise 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. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may or may not raise additional
comments.
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 me at the telephone number
listed
at the end of this letter.
Form 8-K filed July 26, 2005
1. Please file a new Item 4.01 Form 8-K when Weinick Sanders
Leventhal & Co., LLP`s resignation becomes effective. Also, the
new
Form 8-K must include updated disclosures to reflect the actual
resignation date. The new Form 8-K must also include a new
Exhibit
16 letter. Refer to Item 304(a) of Regulation S-K.
2. When you engage a new accountant, please report the engagement
in
a new Form 8-K and comply with the requirements of Regulation S-K
Item 304 (a)(2). In making any disclosures about consultations
with
your new accountants, please ensure you disclose any consultations
up
through the date of engagement.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
Please provide the information requested above within five
business days from the date of this letter. The information
should
be filed as correspondence on EDGAR.
Any questions regarding the above should be directed to me
at
(202) 551-3469.
Sincerely,
Thomas Flinn
Staff Accountant
Ms. Jeanine Folz
Medstrong International Corporation
July 22, 2005
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