SEC Comment Letter for GRAPHCO HOLDINGS CORP (CIK 0001168251) — Jul 22, 2005
GRAPHCO HOLDINGS CORP (CIK 0001168251)
Date: July 22, 2005 · CIK: 0001168251 · Accession: 0000000000-05-037786
AI Filing Summary & Sentiment
File numbers found in text: 000-49647
Letter
Room 4561 July 22, 2005 Mr. Cristian Ivanescu Chief Executive Officer Graphco Holdings Corp. 270 Union Square Driver New Hope, PA 18938
Re: Graphco Holdings Corp. Item 4.01 Form 8-K Filed July 21, 2005 File No. 000-49647
Dear Mr. Ivanescu:
We have reviewed your filing and have the following comments. We may ask you to provide us with more information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. 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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 8-K filed July 21, 2005 1. Please revise the Form 8-K to state the specific date you dismissed J.H. Cohn as your Certifying Accountant. See Item 304(a)(1)(i) of Regulation S-B. 2. Revise your disclosures to state whether during the 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-B. 3. Please file an Exhibit 16 letter from your former accountant, indicating whether or not they agree with your disclosures in the revised Form 8-K.
As appropriate, please respond to these comments within five business days or tell us when you will respond. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. Please furnish a cover letter that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and 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 filing;
* staff comments or changes to disclosure in response to staff comments 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.
You may contact Christine Davis, Staff Accountant, at (202) 551- 3408, Robert Benton, Review Accountant at (202) 551-3804 or me at (202) 551-3489 if you have questions regarding these comments.
Sincerely,
Brad Skinner
Accounting Branch Chief
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Room 4561
July 22, 2005
Mr. Cristian Ivanescu
Chief Executive Officer
Graphco Holdings Corp.
270 Union Square Driver
New Hope, PA 18938
Re: Graphco Holdings Corp.
Item 4.01 Form 8-K
Filed July 21, 2005
File No. 000-49647
Dear Mr. Ivanescu:
We have reviewed your filing and have the following
comments.
We may ask you to provide us with more information so we may
better
understand your disclosure. Please be as detailed as necessary in
your explanation. 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 any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 8-K filed July 21, 2005
1. Please revise the Form 8-K to state the specific date you
dismissed J.H. Cohn as your Certifying Accountant. See Item
304(a)(1)(i) of Regulation S-B.
2. Revise your disclosures to state whether during the 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-B.
3. Please file an Exhibit 16 letter from your former accountant,
indicating whether or not they agree with your disclosures in the
revised Form 8-K.
As appropriate, please respond to these comments within
five
business days or tell us when you will respond. Please submit all
correspondence and supplemental materials on EDGAR as required by
Rule 101 of Regulation S-T. Please furnish a cover letter that
keys
your responses to our comments and provides any requested
information. Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your amendment and 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 filing;
* staff comments or changes to disclosure in response to staff
comments 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.
You may contact Christine Davis, Staff Accountant, at (202)
551-
3408, Robert Benton, Review Accountant at (202) 551-3804 or me at
(202) 551-3489 if you have questions regarding these comments.
Sincerely,
Brad Skinner
Accounting Branch Chief
??
??
??
??
Mr. Cristian Ivanescu
Graphco Holdings Corp.
July 21, 2005
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