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SEC Comment Letter for Grant Life Sciences, Inc. (CIK 0001210336) — Mar 10, 2005

Grant Life Sciences, Inc. (CIK 0001210336)
Date: March 10, 2005 · CIK: 0001210336 · Accession: 0000000000-05-011277

AI Filing Summary & Sentiment

Date
August 24, 2004
Author
Dennis C. Hult
Form
UPLOAD
Company
Grant Life Sciences, Inc. (CIK 0001210336)

Letter

August 24, 2004 Stop 03-06 Mr. Stan Yakatan President and Chief Executive Officer Grant Ventures, Inc. 5792 South 900 East, Suite B Salt Lake City, Utah 84121

Re: Grant Ventures, Inc. SEC File No. 0-50133 Form 8-K, Item 4; Dated July 30/Filed August 6, 2004

Dear Mr. Yakatan :

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in future filings in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. 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 on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

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. 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 filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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.

. . .

1. Please revise the Form to state whether the former accountant resigned, declined to stand for re-election or was dismissed, and the specific date, as required by Item 304(a)(1)(i) of Regulation S-K. It is not sufficient to state that the company "elected not to renew the engagement" of the accountant. Strict adherence to the requirements of Item 304 are required.

2. We noted that the Company filed Item 4 8-K without a header for Item 4 on EDGAR. The header Items on EDGAR, for your filing, were 1, 2 and 7. Please add the filing header Item 4. You may (the company or a legal representative, not a filing processor) send a signed FAX to:

Filer Support 202-504-2474

to request the header correction. The FAX should include the company`s name, file #, and the date it filed the 8-K.

3. To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your revised Form 8-K. We note that the previous accountant`s letter was filed incorrectly as Exhibit 99.3. Refer to Item 601 of Regulation S-K.

The amendment should be filed in response to these comments within 5 business days of the date of this letter.

Any questions regarding the above comments may be directed to myself at (202) 942-2812.

Sincerely,
Dennis C. Hult
Staff Accountant
??

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
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<FILENAME>i48kltr1-grantventure.txt
<DESCRIPTION>ACCOUNTING EXAM COMMENT LTR I48K, HULT - GRANT VENTURES
<TEXT>

	                          August 24, 2004

Stop 03-06

Mr. Stan Yakatan
President and Chief Executive Officer
Grant Ventures, Inc.
5792 South 900 East, Suite B
Salt Lake City, Utah 84121

Re: 	Grant Ventures, Inc.
	SEC File No. 0-50133
	Form 8-K, Item 4; Dated  July 30/Filed August 6, 2004

Dear Mr. Yakatan :

      	We have reviewed your filing and have the following
comments.  Where indicated, we think you should revise your
document
in future filings in response to these comments.  If you disagree,
we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

	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.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

.	.	.

1. Please revise the Form to state whether the former accountant
resigned, declined to stand for re-election or was dismissed, and
the
specific date, as required by Item 304(a)(1)(i) of Regulation S-K.
It is not sufficient to state that the company "elected not to
renew
the engagement" of the accountant.  Strict adherence to the
requirements of Item 304 are required.

2. We noted that the Company filed Item 4 8-K without a header for
Item 4 on EDGAR.  The header Items on EDGAR, for your filing, were
1,
2 and 7.  Please add the filing header Item 4.  You may (the
company
or a legal representative, not a filing processor) send a signed
FAX
to:

Filer Support
202-504-2474

to request the header correction.  The FAX should include the
company`s name, file #, and the date it filed the 8-K.

3. To the extent that you make changes to the Form 8-K to comply
with
our comments, please obtain and file an updated Exhibit 16 letter
from the former accountants stating whether the accountant agrees
with the statements made in your revised Form 8-K.  We note that
the
previous accountant`s letter was filed incorrectly as Exhibit
99.3.
Refer to Item 601 of Regulation S-K.

	The amendment should be filed in response to these comments
within 5 business days of the date of this letter.

	Any questions regarding the above comments may be directed to
myself at (202) 942-2812.

							Sincerely,

							Dennis C. Hult
							Staff Accountant
??

(..continued)

Stan Yakatan
Grant Ventures, Inc.
August 24, 2004
Page 3

</TEXT>
</DOCUMENT>