SEC Company Response from IMEDIA INTERNATIONAL INC (CIK 0001208498) — Apr 18, 2005
IMEDIA INTERNATIONAL INC (CIK 0001208498)
Date: April 18, 2005 · CIK: 0001208498 · Accession: 0001170918-05-000230
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April 18, 2005
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549-0306
Mail Stop 05-11
Attn: Angela J. Halac, Staff Accountant
RE: IMEDIA INTERNATIONAL, INC.
RESPONSES TO STAFF COMMENTS OF APRIL 14, 2005
WITH RESPECT TO:
CURRENT REPORT ON FORM 8-K FILED APRIL 13, 2005
Dear Ms. Halac:
iMedia International, Inc. (the "COMPANY"), has enclosed a copy of an
amended Current Report on Form 8-K (the "AMENDED REPORT") filed today in
response to the Staff's Comments of April 14, 2005 (the "COMMENT LETTER"). In
this letter, we refer to the Staff of the Securities and Exchange Commission as
the "STAFF."
In addition to filing the Amended Report we have enclosed with the
paper submission of this letter a "marked" copy of the amended Current Report,
comparing the amendment to the original filing, and hereby provide
supplementally the following responses in reply to the Comment Letter.
PLEASE AMEND THE FORM 8-K TO STATE WHETHER THE FORMER
ACCOUNTANT RESIGNED, DECLINED TO STAND FOR RE-ELECTION OR WAS
DISMISSED AS REQUIRED BY ITEM 304(a)(1)(i) OF REGULATION S-B.
The Company has complied with the Staff's comment in
paragraph one of the Amended Report.
ITEM 304(a)(1)(iv)(A) OF REGULATION S-B REQUIRES YOU TO
DISCLOSE WHETHER THERE WERE DISAGREEMENTS BETWEEN THE COMPANY
AND THE FORMER ACCOUNTANT FOR THE TWO MOST RECENT FISCAL YEARS
AND ANY SUBSEQUENT INTERIM PERIOD THROUGH THE DATE OF
RESIGNATION. PLEASE REVISE ACCORDINGLY.
The Company has complied with the Staff's comment in
paragraph three of the Amended Report by adding language that
includes the period from the end of the Company's last fiscal
year to April 1, 2005, the date of its accountant's
resignation.
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United States Securities and Exchange Commission
April 18, 2005
Page 2
In connection with our response in this letter, we acknowledge the
following:
o that the Company is responsible for the adequacy and accuracy
of the disclosure in the Amended Report,
o that Staff comments or changes to disclosure in response to
Staff comments do not foreclose the Commission from taking any
action with respect to the Amended Report; and
o that the Company may not assert Staff comments as a defense in
any proceeding initiated by the Commission or any person under
the federal securities law of the United States.
We hope the above has been responsive to the Staff's comments. If you
have any questions or require any additional information or documents, please
telephone me at (818) 444-4503.
Sincerely,
/s/ Frank Unruh
-----------------------
Chief Financial Officer
Enclosures
cc: Gregory Akselrud
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