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SEC Comment Letter for Logistical Support, Inc (CIK 0001158486) — Nov 9, 2004

Logistical Support, Inc (CIK 0001158486)
Date: Nov. 9, 2004 · CIK: 0001158486 · Accession: 0000000000-04-035974

AI Filing Summary & Sentiment

Date
November 9, 2004
Author
Effie Simpson
Form
UPLOAD
Company
Logistical Support, Inc (CIK 0001158486)

Letter

Zip+4 Code: 20549-0305 Via Fax & U.S. Mail Mr. Bruce Littell Chief Executive Officer Logistical Support, Inc. 19734 Dearborn Street Chatsworth, California 91311

RE: Logistical Support, Inc. (the "Company") Forms 8-K filed on November 4, 2004 File No. 0-50222

Dear Mr. Littell:

We have reviewed your filings 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 supplemental 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 us at the telephone numbers listed at the end of this letter.

1. Item 304(a)(1)(ii) of Regulation S-K requires a statement whether the accountant`s report on the financial statements for either of the past two years contained an adverse opinion or a disclaimer of opinion or was qualified or modified as to uncertainty, audit scope or accounting principles; and a description of the nature of each such 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.

2. The disclosure should also state whether during the registrant`s two most recent fiscal years and any subsequent interim period through the date of dismissal there were any disagreements with the former accountant on any matter of accounting principles or practices, financial statement disclosure, or auditing scope or 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. In the event of disagreement(s) and/or reportable event(s), provide the specific disclosures required by Item 304(a)(1)(iv) and (v) of Regulation S-K.

Exhibit 16

3. Please file a letter from your former accountant, indicating whether or not they agree with your disclosures in the Form 8-K.

Other

4. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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 file your supplemental response and amendment via Edgar in response to these comments within five business days of the date of this letter. Please note that if you require longer than five business days to respond, you should contact the staff immediately to request additional time.

You may contact Effie Simpson at (202) 942-2838 or Bob Benton, at (202) 942-1811 if you have any questions.

Sincerely,
Effie Simpson
Staff Accountant

Show Raw Text
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<DESCRIPTION>ACCTG LETTER, 8-K, SIMPSONE, 11/4/04
<TEXT>

November 9, 2004

Zip+4 Code:  20549-0305

Via Fax & U.S. Mail

Mr. Bruce Littell
Chief Executive Officer
Logistical Support, Inc.
19734 Dearborn Street
Chatsworth, California 91311

RE:	Logistical Support, Inc. (the "Company")
	Forms 8-K filed on November 4, 2004
	File No. 0-50222

Dear Mr. Littell:

We have reviewed your filings 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 supplemental
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 us at the telephone numbers listed at the end of this
letter.

1. Item 304(a)(1)(ii) of Regulation S-K requires a statement whether
the accountant`s report on the financial statements for either of the
past two years contained an adverse opinion or a disclaimer of opinion
or was qualified or modified as to uncertainty, audit scope or
accounting principles; and a description of the nature of each such
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.

2. The disclosure should also state whether during the registrant`s
two most recent fiscal years and any subsequent interim period through
the date of dismissal there were any disagreements with the former
accountant on any matter of accounting principles or practices,
financial statement disclosure, or auditing scope or 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.  In the
event of disagreement(s) and/or reportable event(s), provide the
specific disclosures required by Item 304(a)(1)(iv) and (v) of
Regulation S-K.

Exhibit 16

3. Please file a letter from your former accountant, indicating
whether or not they agree with your disclosures in the Form 8-K.

Other

4. We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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 file your supplemental response and amendment via Edgar in
response to these comments within five business days of the date of
this letter.  Please note that if you require longer than five
business days to respond, you should contact the staff immediately to
request additional time.

You may contact Effie Simpson at (202) 942-2838 or Bob Benton, at
(202) 942-1811 if you have any questions.

								Sincerely,

								Effie Simpson
								Staff Accountant

Mr. Bruce Littell
Logistical Support, Inc.
November 9, 2004
Page 1

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