SEC Comment Letter for HOTEL OUTSOURCE MANAGEMENT INTERNATIONAL INC (CIK 0001174814) — Jun 2, 2005
HOTEL OUTSOURCE MANAGEMENT INTERNATIONAL INC (CIK 0001174814)
Date: June 2, 2005 · CIK: 0001174814 · Accession: 0000000000-05-027228
AI Filing Summary & Sentiment
File numbers found in text: 000-50306
Letter
Mail Stop 4561 June 2, 2005 VIA U.S. MAIL AND FAX (212) 480-0717 Ms. Sigal Grinboim Chief Financial Officer Hotel Outsource Management International, Inc. New York, NY 10005
Re: Hotel Outsource Management International, Inc. Form 10-KSB for the year ended December 31, 2004 File No. 000-50306
Dear Ms. Grinboim:
We have reviewed your May 26, 2005 response letter and have the following additional comment. 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 10-KSB for the year ended December 31, 2004
Financial Statements and Notes
Note 11 - Shareholders` Rights
1. We note your response to our prior comment 1. Please tell us how you accounted for the extinguishment of debt for which you issued shares of common stock. In your response, please disclose the difference between the reacquisition price, as represented by the fair value of the shares issued, and the net carrying value of the extinguished debt. Refer to paragraphs 3 and 19-21 of APB 26.
You may contact Matthew Dowling, Staff Accountant, at (202) 551-3467 or me at (202) 551-3403 if you have questions. Please respond to the comments included in this letter within ten business days or tell us when you will provide us with a response. Please file your response on EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
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<TEXT>
Mail Stop 4561
June 2, 2005
VIA U.S. MAIL AND FAX (212) 480-0717
Ms. Sigal Grinboim
Chief Financial Officer
Hotel Outsource Management International, Inc.
New York, NY 10005
Re: Hotel Outsource Management International, Inc.
Form 10-KSB for the year ended December 31, 2004
File No. 000-50306
Dear Ms. Grinboim:
We have reviewed your May 26, 2005 response letter and have
the
following additional comment. 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 10-KSB for the year ended December 31, 2004
Financial Statements and Notes
Note 11 - Shareholders` Rights
1. We note your response to our prior comment 1. Please tell us
how
you accounted for the extinguishment of debt for which you issued
shares of common stock. In your response, please disclose the
difference between the reacquisition price, as represented by the
fair value of the shares issued, and the net carrying value of the
extinguished debt. Refer to paragraphs 3 and 19-21 of APB 26.
You may contact Matthew Dowling, Staff Accountant, at (202)
551-3467 or me at (202) 551-3403 if you have questions. Please
respond to the comments included in this letter within ten
business
days or tell us when you will provide us with a response. Please
file your response on EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
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Ms. Sigal Grinboim
Hotel Outsource Management International, Inc.
June 2, 2005
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