SEC Comment Letter for ONELINK CORP (CIK 0001166161) — Jun 13, 2005
ONELINK CORP (CIK 0001166161)
Date: June 13, 2005 · CIK: 0001166161 · Accession: 0000000000-05-029618
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Mail Stop 4561
June 13, 2005
Via U.S. Mail and Fax (415) 982-1401
Mr. Alan K. Geddes
Chief Financial Officer
One Link 4 Travel, Inc.
One Market Plaza
Spear Tower, 36th Floor
San Francisco, CA 94105
RE: One Link 4 Travel, Inc.
Form 10-KSB for the fiscal year ended December 31, 2004
Filed April 15, 2005
Form 10-KSB/A
Form 10-QSB for the quarterly period ended March 31,
2005
File No. 0-50044
Dear Mr. Geddes:
We have reviewed the above referenced filings and have the
following comments. Please address the following comments in
future
filings. If you disagree, we will consider your explanation as to
why our comment is inapplicable or a future 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 information so we
may
better understand your disclosure. After reviewing this
information,
we may 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.
Item 6. Management`s Discussion and Analysis or Plan of Operation
Liquidity and capital resources, page 21
1. Please clarify to us the status of the convertible notes. In
one
sentence it appears that the notes mature on February 28, 2005,
but
another sentence implies that they are still outstanding at a
later
date.
Report of Independent Registered Public Accounting Firm, page 25
2. Please confirm to us that you have received a manually signed
audit report from your auditors. In future filings please provide
the signature of the auditor within the auditor`s report.
Consolidated Statement of Stockholders` Deficit, page 29
3. Explain to us what is meant by the line item "common stock paid
for but not issued" in 2002. Also, clarify whether the stock was
issued subsequent to 2002.
4. Please explain to us why the receipt of cash for common stock
receivable results in a debit to additional paid in capital in
2004.
Also, please explain the accounting entries recorded over the past
two years related to stock issued with no cash being received.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
letter that keys your responses to our comments and provides any
requested information. Please understand that we may have
additional
comments after reviewing your responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. 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 do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.
You may contact William Demarest, Staff Accountant, at (202)
551-3432 or me at (202) 551-3486 with any questions.
Sincerely,
Daniel L. Gordon
Branch Chief
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Mr. Alan K. Geddes
One Link 4 Travel, Inc.
June 13, 2005
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