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SEC Comment Letter for Digifonica International Corp (CIK 0001211229) — Aug 17, 2004

Digifonica International Corp (CIK 0001211229)
Date: Aug. 17, 2004 · CIK: 0001211229 · Accession: 0000000000-04-026446

AI Filing Summary & Sentiment

File numbers found in text: 000-50178

Date
August 17, 2004
Author
Jennifer Thompson
Form
UPLOAD
Company
Digifonica International Corp (CIK 0001211229)

Letter

<DESCRIPTION>MOLIRIS CORP ITEM 4 8K FILED 8/11/04 REVISED COMMENT LTR THOMPSON August 17, 2004 Mr. Clyde Parks Moliris Corp. d/b/a Advantage Packaging 3221 Collingsworth Street, Suite 140 Fort Worth, Texas 76107

RE: Form 8-K Item 4 filed August 11, 2004 File # 000-50178

Dear Mr. Parks:

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your documents 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 number listed at the end of this letter.

1. We understand that you are working with your former accountants to obtain a letter stating whether they agree with the statements contained in your Item 4 Form 8-K. We have the following comments: * Tell us supplementally if you expect to comply with the ten business day deadline set forth in Item 304(a)(3) of Regulation S-B. It appears that the tenth business day will be August 25, 2004. * When you obtain this letter from your former accountants, please file an amended Item 4 Form 8-K, and attach the letter as Exhibit 16.

*****

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.

In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing. 1. 2. Please file your supplemental response and amendment via EDGAR in response to these comments within 6 business days of the date of this letter. Please note that if you require longer than 6 business days to respond, you should contact the staff immediately to request additional time. You may wish to provide us with marked copies of each amended filing to expedite our review. Direct any questions regarding the above to the undersigned at (202) 824-5259.

Sincerely,
Jennifer Thompson
Staff Accountant
Mr. Parks
August 17, 2004
Page 1

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>moliris8kltr2.txt
<DESCRIPTION>MOLIRIS CORP ITEM 4 8K FILED 8/11/04 REVISED COMMENT LTR THOMPSON
<TEXT>

August 17, 2004

Mr. Clyde Parks
Moliris Corp.
d/b/a Advantage Packaging
3221 Collingsworth Street, Suite 140
Fort Worth, Texas 76107

RE:  	Form 8-K Item 4 filed August 11, 2004
	File # 000-50178

Dear Mr. Parks:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your documents 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 number listed at
the end of this letter.

1. We understand that you are working with your former accountants to
obtain a letter stating whether they agree with the statements
contained in your Item 4 Form 8-K.  We have the following comments:
* Tell us supplementally if you expect to comply with the ten business
day deadline set forth in Item 304(a)(3) of Regulation S-B.  It
appears that the tenth business day will be August 25, 2004.
* When you obtain this letter from your former accountants, please
file an amended Item 4 Form 8-K, and attach the letter as Exhibit 16.

*****

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.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to our
comments on your filing.
1.
2. Please file your supplemental response and amendment via EDGAR in
response to these comments within 6 business days of the date of this
letter.  Please note that if you require longer than 6 business days
to respond, you should contact the staff immediately to request
additional time.  You may wish to provide us with marked copies of
each amended filing to expedite our review.  Direct any questions
regarding the above to the undersigned at (202) 824-5259.

Sincerely,

Jennifer Thompson
Staff Accountant
Mr. Parks
August 17, 2004
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

       DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>