SEC Comment Letter for SOLOMON TECHNOLOGIES INC (CIK 0001240722) — Oct 26, 2004
SOLOMON TECHNOLOGIES INC (CIK 0001240722)
Date: Oct. 26, 2004 · CIK: 0001240722 · Accession: 0000000000-04-034404
AI Filing Summary & Sentiment
Letter
October 5, 2004 Mail Stop 3-6 Peter W. DeVecchis, Jr., President Solomon Technologies, Inc. 1400 L & R Industrial Boulevard Tarpon Springs, Florida 34689
Re: Solomon Technologies, Inc File No. 0-50532 Form 8-K, filed October 26, 2004
Dear Mr. DeVecchis:
We have reviewed the above referenced filing and have the following comments.
We note you have engaged the accounting firm of UHY Advisors, of Hartford Connecticut as principle independent accountants as of October 25, 2004. We also note that the firm of UHY Advisors, of Hartford Connecticut has not applied for registration with the Public Company Accounting Oversight Board (PACOB). Section 102 of the Sarbanes-Oxley Act of 2002 makes it unlawful after October 22, 2003 for any person that is not a registered public accounting firm (i.e. registered with the PACOB) to prepare or issue, or to participate in the preparation or issuance of, any audit report (or review report) with respect to any issuer. You must engage a new accountant that is a publicly registered accounting firm to perform review or audit work for the company. Please file a new Item 4 Form 8-K after you have engaged new independent accountants that are registered with the PACOB. Provide all of the disclosures required by Item 304 of Regulation S-B regarding the period of engagement of UHY Advisors, of Hartford Connecticut, which should include an Exhibit 16 letter from UHY Advisors, of Hartford Connecticut.
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 n0t 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.
Questions with regard to this letter may be addressed to the undersigned at (202) 942-1897.
Sincerely,
Louis M. Canant
Senior Staff Accountant
Office of Electronics and Machinery
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>upload.txt <DESCRIPTION>L.M. CANANT, 8-K FILED 10-26-04 <TEXT> October 5, 2004 Mail Stop 3-6 Peter W. DeVecchis, Jr., President Solomon Technologies, Inc. 1400 L & R Industrial Boulevard Tarpon Springs, Florida 34689 Re: Solomon Technologies, Inc File No. 0-50532 Form 8-K, filed October 26, 2004 Dear Mr. DeVecchis: We have reviewed the above referenced filing and have the following comments. We note you have engaged the accounting firm of UHY Advisors, of Hartford Connecticut as principle independent accountants as of October 25, 2004. We also note that the firm of UHY Advisors, of Hartford Connecticut has not applied for registration with the Public Company Accounting Oversight Board (PACOB). Section 102 of the Sarbanes-Oxley Act of 2002 makes it unlawful after October 22, 2003 for any person that is not a registered public accounting firm (i.e. registered with the PACOB) to prepare or issue, or to participate in the preparation or issuance of, any audit report (or review report) with respect to any issuer. You must engage a new accountant that is a publicly registered accounting firm to perform review or audit work for the company. Please file a new Item 4 Form 8-K after you have engaged new independent accountants that are registered with the PACOB. Provide all of the disclosures required by Item 304 of Regulation S-B regarding the period of engagement of UHY Advisors, of Hartford Connecticut, which should include an Exhibit 16 letter from UHY Advisors, of Hartford Connecticut. 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 n0t 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. Questions with regard to this letter may be addressed to the undersigned at (202) 942-1897. Sincerely, Louis M. Canant Senior Staff Accountant Office of Electronics and Machinery ?? Peter W. DeVecchis, Jr. Solomon Technologies, Inc </TEXT> </DOCUMENT>