SEC Company Response from IJJ CORP (CIK 0001163968) — Oct 13, 2005
IJJ CORP (CIK 0001163968)
Date: Oct. 13, 2005 · CIK: 0001163968 · Accession: 0001144204-05-031592
AI Filing Summary & Sentiment
Referenced dates: September 26, 2005
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CORRESP
1
filename1.htm
Unassociated Document
October
11, 2005
Ms.
Amanda Sledge
Staff
Accountant
Division
of Corporate Finance
U.S.
Securities and Exchange Commission
100
F
Street, N.E.
Washington,
D.C. 20549
Re:
IJJ Corporation
Form 10-KSB for Fiscal Year
Ended
October 31, 2004
Filed March 3,
2005
File No.
0-33515
Dear
Ms.
Sledge:
In
response to your letter dated September 26, 2005 to Mr. Clifford Pope, shown
below is our explanation to your query as to the basis for the Company using
an
audit firm based in Toronto, Ontario, Canada to issue its audit
report.
The
Company is in the process of selecting an Independent Registered Public
Accounting Firm licensed in the United States to perform the audit of the
financial statements for fiscal 2005 to comply with the SEC’s staff
interpretation of Article 2 of Regulation S-X.
At
the
time of the Securities Exchange Agreement (“SEA”) dated October 6, 2003, there
were several consultants and financiers involved in this transaction who
were
mainly from Canada. Consequently, during the process of evaluating the filing
and audit requirements to give effect to the terms of the SEA, a Canadian
accounting firm was suggested as a firm that would be appropriately qualified
to
be the independent auditors as they were considered knowledgeable in US GAAP
and
US GAAS and had other clients who, although were Canadian based, filed in
the
US. The firm is PCOAB registered and has an international affiliation of
firms
both within the United States and worldwide. Management was of the opinion
that
this firm was appropriately qualified to perform the audits despite being
a
Canadian firm.
It
should
be noted that Article 2 is silent as to whether or not the accountant’s state or
country of licensure must coincide with the location of our corporate offices
or
place where we conduct our principal operations. Management was not aware
of the
SEC’s interpretation of Article SX 2-01 that required the audit to be performed
by an auditor licensed in the US.
Should
you have any questions or comments you may contact me at kmiller@mssi2000.com
or
telephone number (301) 370-5246.
Sincerely,
Kevin
L.
Miller
Chief
Financial Officer