SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Company Response from VISCOUNT SYSTEMS INC (CIK 0001158387) — Dec 21, 2005

VISCOUNT SYSTEMS INC (CIK 0001158387)
Date: Dec. 21, 2005 · CIK: 0001158387 · Accession: 0001062993-05-003142

AI Filing Summary & Sentiment

File numbers found in text: 000-49746

Referenced dates: December 21, 2005

Date
December 31, 2004
Author
/s/ Les Fong
Form
CORRESP
Company
VISCOUNT SYSTEMS INC (CIK 0001158387)

Letter

Filed by Automated Filing Services Inc. (604) 609-0244 - Viscount Systems, Inc. - Corresp Robert S. Littlepage United States Securities and Exchange Commission Washington, D.C., 20549

Re: Viscount Systems Inc. Form 10-KSB for the Year ended December 31, 2004 Filed March 31, 2005 File No. 000-49746

Dear Mr. Littlepage,

In response to your letter dated December 21, 2005, our responses to your comments on Form 10-KSB For the Year Ended December 31, 2004 are as follows:

1.

Report of Independent Registered Public Accounting Firm, page F-1

For all future filings of Form 10-KSB and relevant filings, our auditor’s report will refer to “the standards of the Public Company Accounting Oversight Board (United States)” as required by PCAOB Auditing Standard No. 1.

2.

Note 2. Significant Accounting Polices (j) Revenue Recognition

For all future filings of Form 10-KSB and Form 10-QSB, we will include the following paragraph under Revenue Recognition that discloses our revenue recognition policy with respect to our service revenues:

Service revenue is recognized on a straight-line basis over the period covered by the service agreement only after there is a signed agreement to provide service to the Enterphone system, the service fee is fixed or determinable, and collectibility is probable. Cash received from customers in advance of the service period is recorded as deferred revenue.

I hope these responses answer your questions. If you have additional comments, please contact me at 604-323-7228, or fax me at 604-327-9446.

Sincerely,
/s/ Les Fong
Les Fong
Chief Financial Officer

Show Raw Text
CORRESP
1
filename1.htm

   Filed by Automated Filing Services Inc. (604) 609-0244 - Viscount Systems, Inc. - Corresp

Robert S. Littlepage
United States
Securities and
Exchange Commission
Washington, D.C., 20549

Re: Viscount Systems Inc.
Form 10-KSB for the Year ended
December 31, 2004
Filed March 31, 2005
File No. 000-49746

Dear Mr. Littlepage,

In response to your letter dated December 21, 2005, our
responses to your comments on Form 10-KSB For the Year Ended December 31, 2004
are as follows:

    1.

      Report of Independent Registered Public Accounting
      Firm, page F-1

      For all future filings of Form 10-KSB and relevant
      filings, our auditor’s report will refer to “the standards of the Public
      Company Accounting Oversight Board (United States)” as required by PCAOB
      Auditing Standard No. 1.

    2.

      Note 2. Significant Accounting Polices (j) Revenue
      Recognition

      For all future filings of Form 10-KSB and Form 10-QSB, we
      will include the following paragraph under Revenue Recognition that
      discloses our revenue recognition policy with respect to our service
      revenues:

      Service revenue is recognized on a straight-line basis
      over the period covered by the service agreement only after there is a
      signed agreement to provide service to the Enterphone system, the service
      fee is fixed or determinable, and collectibility is probable. Cash
      received from customers in advance of the service period is recorded as
      deferred revenue.

I hope these responses answer your questions. If you have
additional comments, please contact me at 604-323-7228, or fax me at
604-327-9446.

Sincerely,

/s/ Les Fong
Les Fong
Chief Financial Officer