SEC Company Response from ELITE FLIGHT SOLUTIONS INC (CIK 0001161723) — Nov 30, 2005
ELITE FLIGHT SOLUTIONS INC (CIK 0001161723)
Date: Nov. 30, 2005 · CIK: 0001161723 · Accession: 0000898432-05-000980
AI Filing Summary & Sentiment
Referenced dates: June 21, 2005
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ELITE FLIGHT SOLUTIONS, INC.
710 THIRD STREET
ROANOKE, VIRGINIA 24061
November 29, 2005
Ms. Linda Cvrkel
Securities and Exchange Commission
450 5th Street NW
Washington, DC 20549
Re: Elite Flight Solutions, Inc.
Form 10-K for the year ended June 30, 2004
File No.: 1-31231
Dear Ms. Cvrkel:
This letter is in response to your letter dated June 21, 2005.
Comment 1:
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We note your response to comment 1. In addition to identifying the components of
other operating expenses, discuss in future filings the changes in your
operating results for the periods being compared to provide a meaningful
discussion to the reader of those significant items impacting your results. Tell
us, in great detail, and discuss in future filings, the services that were
provided to you that are included in professional and consulting fees of
$2,235,627. We may have further comment based on your response.
Response:
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The breakdown for the professional and consulting fees are as follows:
Accounting Fees: $47,224
Legal and Filing Fees: $298,505
Financial Consulting Fees: $278,951
Loan Fees : $1,563,739
Professional Fees: $26,932
Other Professional Fees: $20,281
Total: $2,235,627
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Comment 2:
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We note from your disclose in Note 9 to the financial statements that you
anticipate filing a Registration Statement on Form SB-2. Tell us when you plan
to file such Registration Statement and whether you or Cornell Capital Partners
LP have analyzed whether the filing of that Registration Statement would be
consistent with Section 5 of the Securities Act.
Response:
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The Company intends to terminate its prior financing arrangement with Cornell
Capital Partners LP and negotiate new financing arrangements. Currently, the
Company does not know when it may file a registration statement.
Sincerely,
/s/ Bruce Edwards
Bruce Edwards
President
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