SEC Comment Letter for TREND TECHNOLOGY CORP (CIK 0001137239) — Aug 16, 2005
TREND TECHNOLOGY CORP (CIK 0001137239)
Date: Aug. 16, 2005 · CIK: 0001137239 · Accession: 0000000000-05-042297
AI Filing Summary & Sentiment
Letter
August 11, 2005 Mail Stop 3561 Mr. Gerald J. Shields, President Trend Technology Corporation Suite 1020 510 Burrard Street Vancouver, BC, V6C 3A8, Canada
Re: Trend Technology Corporations Item 4.01 Form 8-K dated August 8, 2005 Filed August 9, 2005 File No. 0-50978
Dear Mr. Shields:
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 more information so we may better understand your disclosure. After reviewing this information, we may 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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Item 304(a)(1)(ii) of Regulation S-B requires you to disclose whether the former accountant`s report on your financial statements for either of the past two years contained an adverse opinion, a disclaimer of opinion, or was qualified or modified as to uncertainty, audit scope or accounting principles and, if so, describe the nature of each adverse opinion, disclaimer of opinion, modification or qualification. This would include disclosure of uncertainty regarding the ability to continue as a going concern in the accountant`s report. Please revise.
Item 304(a)(1)(iv)(A) of Regulation S-B requires you to disclose whether during your two most recent fiscal years and any subsequent interim period before the date your former auditor resigned, declined to stand for re-election or was dismissed, you had any disagreements with your former auditor on any matter of accounting principle or practice, financial statement disclosure, or auditing scope of procedure, which disagreement(s), if not resolved to the satisfaction of the former accountant, would have caused it to make reference to the subject matter of the disagreement(s) in connection with its reports.
To the extent that you amend the Form 8-K to comply with our comments, please obtain and file and updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with your Item 304 disclosures, or the extent to which the accountant does not agree.
As appropriate, please file your supplemental response and amendment via EDGAR in response to these comments within five business days after the date of this letter or tell us when you will provide us with a response. Please contact the staff immediately if you require longer than 5 business days to respond. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
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 and 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.
If you have any questions, please call the undersigned at (202) 551-3237.
Sincerely,
Maureen Bauer
Staff Accountant
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
August 11, 2005
Mail Stop 3561
Mr. Gerald J. Shields, President
Trend Technology Corporation
Suite 1020
510 Burrard Street
Vancouver, BC, V6C 3A8, Canada
Re: Trend Technology Corporations
Item 4.01 Form 8-K dated August 8, 2005
Filed August 9, 2005
File No. 0-50978
Dear Mr. Shields:
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 more
information so we may better understand your disclosure. After
reviewing this information, we may 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 any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Item 304(a)(1)(ii) of Regulation S-B requires you to
disclose
whether the former accountant`s report on your financial
statements
for either of the past two years contained an adverse opinion, a
disclaimer of opinion, or was qualified or modified as to
uncertainty, audit scope or accounting principles and, if so,
describe the nature of each adverse opinion, disclaimer of
opinion,
modification or qualification. This would include disclosure of
uncertainty regarding the ability to continue as a going concern
in
the accountant`s report. Please revise.
Item 304(a)(1)(iv)(A) of Regulation S-B requires you to
disclose whether during your two most recent fiscal years and any
subsequent interim period before the date your former auditor
resigned, declined to stand for re-election or was dismissed, you
had
any disagreements with your former auditor on any matter of
accounting principle or practice, financial statement disclosure,
or
auditing scope of procedure, which disagreement(s), if not
resolved
to the satisfaction of the former accountant, would have caused it
to
make reference to the subject matter of the disagreement(s) in
connection with its reports.
To the extent that you amend the Form 8-K to comply with our
comments, please obtain and file and updated Exhibit 16 letter
from
the former accountants stating whether the accountant agrees with
your Item 304 disclosures, or the extent to which the accountant
does
not agree.
As appropriate, please file your supplemental response and
amendment via EDGAR in response to these comments within five
business days after the date of this letter or tell us when you
will
provide us with a response. Please contact the staff immediately
if
you require longer than 5 business days to respond. You may wish
to
provide us with marked copies of the amendment to expedite our
review. Please furnish a cover letter with your amendment that
keys
your responses to our comments and provides any requested
information. Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.
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 and 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.
If you have any questions, please call the
undersigned
at (202) 551-3237.
Sincerely,
Maureen Bauer
Staff Accountant
??
??
??
??
Mr. Gerald J. Shields
Trend Technology Corporation
August 11, 2005
Page 3
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306
DIVISION OF
CORPORATION FINANCE
</TEXT>
</DOCUMENT>