SEC Company Response from INTERNATIONAL CARD ESTABLISHMENT INC (CIK 0001156337) — Aug 4, 2005
INTERNATIONAL CARD ESTABLISHMENT INC (CIK 0001156337)
Date: Aug. 4, 2005 · CIK: 0001156337 · Accession: 0001092306-05-000391
AI Filing Summary & Sentiment
File numbers found in text: 000-33129
Letter
Re: International Card Establishment, Inc. Item 4.01 Form 8-K filed July 22, 2005 (File No. 000-33129)
SICHENZIA ROSS FRIEDMAN FERENCE LLP ATTORNEYS AT LAW
August 4, 2005
VIA EDGAR
Room 4561
United States Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, DC 20549
Attention: Stephen Kirkorian, Accounting Branch Chief Morgan Youngwood Melissa Walsh
Ladies and Gentlemen:
The following responses address the comments of the reviewing Staff of the Commission as set forth in the comment letter of July 29, 2005 relating to the Item 4.01 Current Report on Form 8-K of International Card Establishment, Inc. (the "Company"). On behalf of the Company, we respond as follows.
ITEM 4.01 FORM 8-K FILED ON JULY 22, 2005
1. We note that Kyle L. Tingle, LLC was advised by the Company that they would no longer serve as the auditors for the Company. Revise your disclosure to specifically state whether the former accountant resigned, declined to stand for re-election or was dismissed in accordance with Item 304(a)(1)(i) of Regulation S-B. Also, provide an updated letter from the former accountant as to whether or not it agrees with the statements contained in the amended filing.
RESPONSE:
We have revised the disclosure to specifically state that Kyle L. Tingle, LLC was dismissed as the auditors for the Company in accordance with Item 304(a)(1)(i) of Regulation S-B. In addition, we have filed an updated letter from the former accountant stating that it agrees with the statements contained in the amended filing.
The Company hereby acknowledges the following:
o the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
o 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
o 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.
Very truly yours,
/s/ ERIC A. PINERO
________________________
Eric A. Pinero, Esq.
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SICHENZIA ROSS FRIEDMAN FERENCE LLP
ATTORNEYS AT LAW
August 4, 2005
VIA EDGAR
Room 4561
United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, DC 20549
Attention: Stephen Kirkorian, Accounting Branch Chief
Morgan Youngwood
Melissa Walsh
Re: International Card Establishment, Inc.
Item 4.01 Form 8-K filed July 22, 2005 (File No. 000-33129)
Ladies and Gentlemen:
The following responses address the comments of the reviewing Staff of
the Commission as set forth in the comment letter of July 29, 2005 relating to
the Item 4.01 Current Report on Form 8-K of International Card Establishment,
Inc. (the "Company"). On behalf of the Company, we respond as follows.
ITEM 4.01 FORM 8-K FILED ON JULY 22, 2005
1. We note that Kyle L. Tingle, LLC was advised by the Company that they
would no longer serve as the auditors for the Company. Revise your
disclosure to specifically state whether the former accountant
resigned, declined to stand for re-election or was dismissed in
accordance with Item 304(a)(1)(i) of Regulation S-B. Also, provide an
updated letter from the former accountant as to whether or not it
agrees with the statements contained in the amended filing.
RESPONSE:
We have revised the disclosure to specifically state that Kyle L.
Tingle, LLC was dismissed as the auditors for the Company in accordance with
Item 304(a)(1)(i) of Regulation S-B. In addition, we have filed an updated
letter from the former accountant stating that it agrees with the statements
contained in the amended filing.
The Company hereby acknowledges the following:
o the Company is responsible for the adequacy and accuracy of the
disclosure in the filing;
o 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
o 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.
Very truly yours,
/s/ ERIC A. PINERO
________________________
Eric A. Pinero, Esq.
SRFF
1065 AVENUE OF THE AMERICAS * NEW YORK, NEW YORK 10018
T 212 930 9700 * F 212 930 9725 * WWW.SRFF.COM
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