SEC Comment Letter for ZONE 4 PLAY INC (CIK 0001175442) — Apr 22, 2005
ZONE 4 PLAY INC (CIK 0001175442)
Date: April 22, 2005 · CIK: 0001175442 · Accession: 0000000000-05-019950
AI Filing Summary & Sentiment
File numbers found in text: 333-122727
Letter
Mail Stop 4-6 April 19, 2005 Shimon Citron Chief Executive Officer Zone 4 Play, Inc. 103 Foulk Road Wilmington, DE 19803
Re: Zone 4 Play, Inc. Amendment No. 1 to Registration Statement on Form SB-2 Filed on April 5, 2005 File No. 333-122727
Dear Mr. Citron:
We have reviewed your responses and have the following comment. 1. See prior comment 3. Your supplemental response indicates that the shares held by First New York Securities, a registered broker- dealer, were acquired in the ordinary course of business. Because the shares were not received as compensation, First New York Securities must be named as an underwriter. Please revise to state unambiguously both here and in the plan of distribution on page 12 that the broker-dealer selling shareholder is an underwriter.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an informed 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.
Any questions should be directed to Maryse Mills-Apenteng at (202) 942-1861. If you need further assistance, you may contact me at (202) 942-1800.
Sincerely,
Barbara C. Jacobs
Assistant Director
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Mail Stop 4-6
April 19, 2005
Shimon Citron
Chief Executive Officer
Zone 4 Play, Inc.
103 Foulk Road
Wilmington, DE 19803
Re: Zone 4 Play, Inc.
Amendment No. 1 to Registration Statement on Form SB-2
Filed on April 5, 2005
File No. 333-122727
Dear Mr. Citron:
We have reviewed your responses and have the following
comment.
1. See prior comment 3. Your supplemental response indicates that
the shares held by First New York Securities, a registered broker-
dealer, were acquired in the ordinary course of business. Because
the shares were not received as compensation, First New York
Securities must be named as an underwriter. Please revise to
state
unambiguously both here and in the plan of distribution on page 12
that the broker-dealer selling shareholder is an underwriter.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.
Any questions should be directed to Maryse Mills-Apenteng at
(202) 942-1861. If you need further assistance, you may contact
me
at (202) 942-1800.
Sincerely,
Barbara C. Jacobs
Assistant Director
cc: Via facsimile: 617-338-2880
Howard E. Berkenblit, Esq.
Z.A.G./S&W LLP
One Post Office Square
Boston, MA 02109
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Zone 4 Play
April 19, 2005
Page 2 of 2
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