SEC Comment Letter for Polomar Health Services, Inc. (PMHS) (CIK 0001265521) (PMHS) — Jul 23, 2010
Polomar Health Services, Inc. (PMHS) (CIK 0001265521)
Date: July 23, 2010 · CIK: 0001265521 · Accession: 0000000000-10-041947
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-152439
Letter
July 23, 2010 John Jan Popovic President Healthmed Services Ltd. 1250 Oakmead, #210 Sunnyvale, CA 94085 Re: Healthmed Services Ltd. Post-Effective Amendment No.1 to Registration Statement on Form S-1 Filed July 14, 2010 File No. 333-152439
Dear Mr. Popovic: We have limited our review of your registra tion statement to those issues we have addressed in our comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. Where you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your re gistration statement and the information you provide in response to these comments, we may have additional comments. General
1. Your registration statement was initially de clared effective August 4, 2008 with audited financial statements through the fiscal year ended December 31, 2007. Please advise as to whether any sales have been made after May 4, 2009 under this registration statement. 2. Please ensure that a currently dated consen t of your Independent Registered Public Accounting Firm is filed as an exhi bit to your regist ration statement.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and all applicable Securities Act rules 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.
John Jan Popovic Healthmed Services Ltd. July 23, 2010 Page 2
Notwithstanding our comments, before we can declare the amended registration statement effective, the company should pr ovide us with a letter, acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the filing effective, it does not foreclose the Co mmission from taking any action with respect to the filing;
• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
• the company may not assert staff comments a nd the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please direct all questions to Stephani Bouvet at (202) 551-3545 or, in her absence, to me at (202) 551-3462.
S i n c e r e l y , Mark P. Shuman Branch Chief – Legal
cc: Via facsimile to: (602) 633-1617
Scott Lawler, Esq.
Show Raw Text
July 23, 2010
John Jan Popovic President Healthmed Services Ltd. 1250 Oakmead, #210 Sunnyvale, CA 94085
Re: Healthmed Services Ltd.
Post-Effective Amendment No.1 to
Registration Statement on Form S-1 Filed July 14, 2010
File No. 333-152439
Dear Mr. Popovic:
We have limited our review of your registra tion statement to those issues we have
addressed in our comments. In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. Where you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.
General
1. Your registration statement was initially de clared effective August 4, 2008 with audited
financial statements through the fiscal year ended December 31, 2007. Please advise as
to whether any sales have been made after May 4, 2009 under this registration statement.
2. Please ensure that a currently dated consen t of your Independent Registered Public
Accounting Firm is filed as an exhi bit to your regist ration statement.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules 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.
John Jan Popovic Healthmed Services Ltd. July 23, 2010 Page 2
Notwithstanding our comments, before we can declare the amended registration
statement effective, the company should pr ovide us with a letter, acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;
• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and
• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please direct all questions to Stephani Bouvet at (202) 551-3545 or, in her absence, to me
at (202) 551-3462.
S i n c e r e l y ,
Mark P. Shuman
Branch Chief – Legal
cc: Via facsimile to: (602) 633-1617
Scott Lawler, Esq.