SEC Company Response from Uni-Pixel (CIK 0001171012) — May 24, 2005
Uni-Pixel (CIK 0001171012)
Date: May 24, 2005 · CIK: 0001171012 · Accession: 0001047469-05-015687
AI Filing Summary & Sentiment
Referenced dates: May 20, 2005
Letter
Division of Corporation Finance Securities and Exchange Commission Uni-Pixel, Inc. Amendment No. 2 to Form 10-SB Filed April 27, 2005 File No. 0-49737
Dear Mr. Jones:
On behalf of our client, Uni-Pixel, Inc. (the "Company"), we are responding to your comment letter dated May 20, 2005. For your convenience, we have repeated the comment of the Staff letter below and followed the comment with the response of the Company.
Form 10-QSB for period ending March 31, 2005
Item 3. Controls and Procedures—Page 15
1. We note your disclosure that management concluded as of the evaluation date that your disclosure controls and procedures were "effective in timely providing each of [your president and chief financial officer] with material information relating to us (including our consolidated subsidiary) required to be included in our Exchange Act filings." Please note that all language that appears following the word "effective" must be consistent with the language that appears in the definition of "disclosure controls and procedures" set forth in Rule 13a-15(e) of the Exchange Act. In future filings, please clarify whether your Chief Executive Officer and Chief Financial Officer concluded that your disclosure controls and procedures are effective to ensure that information required to be disclosed in the reports you file or submit under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in the Commission's rules and forms, and that it is accumulated and communicated to management, including your Chief Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.
The Company agrees to clarify in future filings whether its Chief Executive Officer and Chief Financial Officer concluded that the Company's disclosure controls and procedures are effective to ensure that information required to be disclosed by the Company in the reports that it files or submits under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in the Commission's rules and forms, and that such information is accumulated and communicated to the Company's management, including the Company's Chief Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.
* * *
If you have any questions regarding these responses, please call me at (512) 370-2837 or Joelle S. Boehle at (512) 370-2868.
Sincerely,
/s/ DARRELL R. WINDHAM Darrell R. Windham
Show Raw Text
CORRESP
1
filename1.htm
[Winstead Sechrest & Minick P.C. Letterhead]
May 24,
2005
direct dial: 512.370.2837
dwindham@winstead.com
Mr. Thomas
A. Jones
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 03-06
450 Fifth Street, N.W.
Washington, D.C. 20549
Re:
Uni-Pixel, Inc.
Amendment No. 2 to Form 10-SB
Filed April 27, 2005
File No. 0-49737
Dear
Mr. Jones:
On
behalf of our client, Uni-Pixel, Inc. (the "Company"), we are responding to your comment letter dated May 20, 2005. For your convenience, we have repeated
the comment of the Staff letter below and followed the comment with the response of the Company.
Form 10-QSB for period ending March 31, 2005
Item 3. Controls and Procedures—Page 15
1. We
note your disclosure that management concluded as of the evaluation date that your disclosure controls and procedures were "effective in timely providing each of
[your president and chief financial officer] with material information relating to us (including our consolidated subsidiary) required to be included in our Exchange Act
filings." Please note that all language that appears following the word "effective" must be consistent with the language that appears in the definition of "disclosure controls and procedures" set
forth in Rule 13a-15(e) of the Exchange Act. In future filings, please clarify whether your Chief Executive Officer and Chief Financial Officer concluded that your disclosure
controls and procedures are effective to ensure that information required to be disclosed in the reports you file or submit under the Exchange Act is recorded, processed, summarized and reported
within the time periods specified in the Commission's rules and forms, and that it is accumulated and communicated to management, including your Chief Executive Officer and Chief Financial Officer, as
appropriate to allow timely decisions regarding required disclosure.
The Company agrees to clarify in future filings whether its Chief Executive Officer and Chief Financial Officer concluded that the Company's disclosure controls
and procedures are effective to ensure that information required to be disclosed by the Company in the reports that it files or submits under the Exchange Act is recorded, processed, summarized and
reported within the time periods specified in the Commission's rules and forms, and that such information is accumulated and communicated to the Company's management, including the Company's Chief
Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.
* * *
If
you have any questions regarding these responses, please call me at (512) 370-2837 or Joelle S. Boehle at (512) 370-2868.
Sincerely,
/s/ DARRELL R. WINDHAM Darrell R. Windham
DRW:jsb
cc:
Reed J. Killion
James A. Tassone
Mary Beth Breslin