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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

Date
October 31, 2004
Author
Kevin
Form
CORRESP
Company
IJJ CORP (CIK 0001163968)

Letter

Division of Corporate Finance IJJ Corporation Form 10-KSB for Fiscal Year Ended October 31, 2004 Filed March 3, 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

Show Raw Text
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