SEC Comment Letter for SILVER SCREEN STUDIOS INC (CIK 0001262456) — Feb 7, 2005
SILVER SCREEN STUDIOS INC (CIK 0001262456)
Date: Feb. 7, 2005 · CIK: 0001262456 · Accession: 0000000000-05-006112
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February 7, 2005
Mail Stop 0409
Via U.S. Mail and Fax (404) 522-1447
Mr. Otto Fletcher
Chief Executive Officer
Silver Screen Studios, Inc.
101 Marietta St., Suite 1070
Atlanta, GA 30303
Re: Silver Screen Studios, Inc. Form 8-K/A filed on January 20,
2005
Dear Mr. Fletcher:
We have reviewed your filing and have the following comments. In
our
comments, we 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 me at the telephone number
listed
at the end of this letter.
General
1. Please revise to file your amendment to Form 8-K as Item 4.01
instead of Item 5.02.
Disagreements
2. Please revise to clarify the periods in which there were no
disagreements with Norman Ross, P.C. on any matter of accounting
principles or practices, financial disclosures, or auditing scope
or
procedure. For example, state whether during the registrant`s two
most recent fiscal years and any subsequent interim period through
December 3, 2004, there were any disagreements with Norman Ross,
P.C.
on any matter of accounting principles or practices, financial
disclosures, or auditing scope or procedure.
Exhibit 16:
3. Please file a letter from Norman Ross, P.C., indicating whether
or
not they agree with your disclosures in the amended Form 8-K.
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 comment, 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.
Please provide the supplemental information requested above within
10
business days from the date of this letter. The supplemental
information should be filed as correspondence on EDGAR. The
amendment requested above should be filed as promptly as possible
and
should be reviewed by the newly engaged accountants before filing
with the Commission.
You may reach me at (202) 942-2913 with any questions.
Sincerely,
Andrew Mew
Staff Accountant
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Silver Screen Studios, Inc.
February 7, 2005
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