SEC Company Response from LDG INC (CIK 0001268659) — Dec 28, 2005
LDG INC (CIK 0001268659)
Date: Dec. 28, 2005 · CIK: 0001268659 · Accession: 0001002014-05-000818
AI Filing Summary & Sentiment
File numbers found in text: 333-122666
Letter
Office of Emerging Growth Companies Securities and Exchange Commission Washington, D.C. 20549 RE: LDG, Inc. Form SB-2 SEC file no. 333-122666
Dear Mr. Reynolds:
Please be advised that I represent LDG, Inc. (the "Company"). I am writing to you as a result of impasses the Company has encountered with respect to comments issued on your behalf by Michael Karney and/or John Zitko.
Messrs Karney and/or Zitko have concluded that the Company is a blank check corporation. This conclusion is contrary to the law. Further, the Company is operating and generating revenues. I would ask you to review the Company's Form SB-2 and correct this erroneous conclusion by Messrs Karney and Zitko.
Next, Messrs Karney and/or Zitko have been requesting "factual" information to support the Company's private placement of securities pursuant to Reg. 506 of the Securities Act of 1933. The Company believes that it has disclosed all of the facts regarding the private placement as required by Item 701 of Reg. S-B. In the last letter of comments from Messrs Karney and Zitko, it appears they want a statement of facts pertaining to each individual private placee and that an omnibus paragraph is unacceptable.
Securities and Exchange Commission
RE: LDG, Inc.
Form SB-2
No. 333-122666
December 28, 2005
Page 2
As you know, over the years I have represented a number of corporations that have filed Form SB-2 registration statements with the SEC. Several of those registration statements have been reviewed by your branch. In the course of my interaction with your branch, I have never found the comment process to be as arduous as the process created by Messrs Karney and/or Zitko.
Under the circumstances, I would like you to intervene and review their actions. Thereafter, I would like to have a conference call with you, personally, in order to resolve the outstanding comments and bring the comment process to a conclusion.
Thank you for your cooperation. I look forward to your reply.
Yours truly,
/s/ Conrad C. Lysiak
Conrad C. Lysiak
CCL:jtb
cc: LDG, Inc.
Show Raw Text
CORRESP 1 filename1.htm CONRAD C. LYSIAK, Esq. - CONRAD C. LYSIAK Attorney and Counselor at Law 601 West First Avenue Suite 503 Spokane, Washington 99201 (509) 624-1475 FAX (509) 747-1770 EMAIL CCLYSIAK@QWEST.NET December 28, 2005 Mr. John Reynolds Assistant Director Office of Emerging Growth Companies Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 RE: LDG, Inc. Form SB-2 SEC file no. 333-122666 Dear Mr. Reynolds: Please be advised that I represent LDG, Inc. (the "Company"). I am writing to you as a result of impasses the Company has encountered with respect to comments issued on your behalf by Michael Karney and/or John Zitko. Messrs Karney and/or Zitko have concluded that the Company is a blank check corporation. This conclusion is contrary to the law. Further, the Company is operating and generating revenues. I would ask you to review the Company's Form SB-2 and correct this erroneous conclusion by Messrs Karney and Zitko. Next, Messrs Karney and/or Zitko have been requesting "factual" information to support the Company's private placement of securities pursuant to Reg. 506 of the Securities Act of 1933. The Company believes that it has disclosed all of the facts regarding the private placement as required by Item 701 of Reg. S-B. In the last letter of comments from Messrs Karney and Zitko, it appears they want a statement of facts pertaining to each individual private placee and that an omnibus paragraph is unacceptable. Securities and Exchange Commission RE: LDG, Inc. Form SB-2 No. 333-122666 December 28, 2005 Page 2 As you know, over the years I have represented a number of corporations that have filed Form SB-2 registration statements with the SEC. Several of those registration statements have been reviewed by your branch. In the course of my interaction with your branch, I have never found the comment process to be as arduous as the process created by Messrs Karney and/or Zitko. Under the circumstances, I would like you to intervene and review their actions. Thereafter, I would like to have a conference call with you, personally, in order to resolve the outstanding comments and bring the comment process to a conclusion. Thank you for your cooperation. I look forward to your reply. Yours truly, /s/ Conrad C. Lysiak Conrad C. Lysiak CCL:jtb cc: LDG, Inc.