SEC Company Response from SIN HOLDINGS INC (CIK 0001140414) — Oct 26, 2005
SIN HOLDINGS INC (CIK 0001140414)
Date: Oct. 26, 2005 · CIK: 0001140414 · Accession: 0001021890-05-000188
AI Filing Summary & Sentiment
File numbers found in text: 000-49752
Referenced dates: September 29, 2005
Letter
Ms. Jessica Barberich Staff Accountant United States Securities and Exchange Commission 100 F St. Street, NE Washington, DC 20549 SIN Holdings, Inc. Form 10-KSB for Fiscal Year Ended December 31, 2004 Filed March 16, File No. 000-49752
RE:
Dear Ms. Barberich:
Thank you for your letter dated September 29, 2005. I will respond to your inquiries by referencing the paragraph numbers from your letter.
1.
Our auditors did not include an explanatory paragraph regarding SIN Holdings, Inc.‘s (“SIN” or the “Company”) ability to continue as a going concern in their audit report because, although our auditors did not look at a formal contractual obligation by Desert Bloom Investments, Inc. (“Desert Bloom”) to continue funding the Company, they noted that, as a controlling shareholder, Desert Bloom had made and continued to make loans to SIN and expressed its intention to continue to do so. They further noted that the loans made to the Company by Desert Bloom were extended upon maturity and that the loans could be converted to capital if needed. Therefore they agreed with the Company’s assertion that substantial doubt about the Company’s ability to continue as a going concern did not exist and there was no need for a going concern qualification or explanatory paragraph with reference to a note with managements’ plans to mitigate the going concern.
2.
In assessing goodwill for impairment, we projected future cash flows in the form of revenues and therefore goodwill does not show impairment at this time. Our projection is supported by an evaluation of the visitor activity on our web site. The number of visitors to our web site continues to increase and it is this activity that supports the integrity of our assets and is an objective indicator that the Company has the potential to generate future revenues.
SIN Holdings, Inc. acknowledges
°
that we are responsible for the adequacy and accuracy of the disclosures in the filing,
°
that staff comments or changes to disclosure in response to staff comments to not foreclose the Commission from taking any action with respect to the filings and
°
that 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.
Best regards,
/s/ Steve
Sinohui
President
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CORRESP
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SIN Holdings, Inc. 10/4/2005 SEC Correspondence
SIN
Holdings, Inc.
P. O. Box 370912
Denver, Colorado 80237
(303) 763-7527
October 4, 2005
Ms. Jessica Barberich
Staff Accountant
United States Securities and Exchange Commission
100 F St. Street, NE
Washington, DC 20549
RE:
SIN
Holdings, Inc.
Form 10-KSB for Fiscal Year Ended December 31, 2004
Filed March 16,
2005
File No. 000-49752
Dear Ms.
Barberich:
Thank
you for your letter dated September 29, 2005. I will respond to your inquiries
by referencing the paragraph numbers from your letter.
1.
Our auditors did not include an explanatory paragraph regarding SIN Holdings,
Inc.‘s (“SIN” or the “Company”) ability to continue as
a going concern in their audit report because, although our auditors did not
look at a formal contractual obligation by Desert Bloom Investments, Inc.
(“Desert Bloom”) to continue funding the Company, they noted that, as
a controlling shareholder, Desert Bloom had made and continued to make loans to
SIN and expressed its intention to continue to do so. They further noted that
the loans made to the Company by Desert Bloom were extended upon maturity and
that the loans could be converted to capital if needed. Therefore they agreed
with the Company’s assertion that substantial doubt about the
Company’s ability to continue as a going concern did not exist and there
was no need for a going concern qualification or explanatory paragraph with
reference to a note with managements’ plans to mitigate the going concern.
2.
In assessing goodwill for impairment, we projected future cash flows in the form
of revenues and therefore goodwill does not show impairment at this time. Our
projection is supported by an evaluation of the visitor activity on our web
site. The number of visitors to our web site continues to increase and it is
this activity that supports the integrity of our assets and is an objective
indicator that the Company has the potential to generate future revenues.
SIN
Holdings, Inc. acknowledges
°
that
we are responsible for the adequacy and accuracy of the disclosures in the filing,
°
that
staff comments or changes to disclosure in response to staff comments to not foreclose
the Commission from taking any action with respect to the filings and
°
that
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.
Best regards,
/s/ Steve
Sinohui
President