SEC Company Response from S.E. ASIA TRADING COMPANY, INC. (CIK 0001292087) — Dec 3, 2004
S.E. ASIA TRADING COMPANY, INC. (CIK 0001292087)
Date: Dec. 3, 2004 · CIK: 0001292087 · Accession: 0001121781-04-000319
AI Filing Summary & Sentiment
File numbers found in text: 333-118898
Referenced dates: October 6, 2004
Letter
RE: S.E. Asia Trading Company, Inc. Form SB-1 File No. 333-118898
Dear Mr. Bhaumil, Ms. Quarles and Mr. Owings:
Following are responses to your comment letter dated October 6, 2004.
Prospectus Inside Cover Page
1.
The reference to NASDAQ has been deleted and a clarification made as to when we intend to file for listing (Page 1)
2.
The page reference for the APlan of Operations@ has been corrected (page 3)
3.
The reference to the going concern opinion has been relocated to AOur Company@ section. And clarification made as to why that was issued (Page 2)
Risk Factors
4.
We have stated that the penny stock rules may adversely affect the ability of both the broker-dealers to sell the securities, etc. (page 6)
Plan of Distribution
5.
We have clarified that we will not cash the offering checks unless and until we raise the minimum offering (page 9)
Use of Proceeds
6.
The salary of Mr. Miller has been clarified (page 11)
Business Strategy
7.
We have clarified that we will open >one= new store during the next twelve months (page 12)
Management=s Discussion and Plan of Operations
Generating Sufficient Revenue
8.
We have provided justification for our belief that >more and more= people are responding to our advertising (page 15)
9.
We have specifically stated that we will be able to generate sufficient cash to sustain our operations (page 15)
Financial Needs
10.
We have amended our discussion of sales and gross profit (page 16)
11.
We have provided supplementally a copy of the article on the growth in Rockwall county.
Significant Parties
12.
The percentage of each shareholder have been included (page 18)
13.
The middle initial of Charles Smith has been inserted (page 19)
Financial Statements for the Period January 28, 2004 through May 31, 2004
14.
Updated financials have been included in accordance with Item 310(a) of Regulation S-B. They are nor audited per discussion with Mr. Adam Phippen
Financial Statemented through September 30, 2004
Balance Sheet as of September 30, 2004
15.
The total current assets figure is corrected
Statement of Loss for the period through September 30, 2004
16.
A description for the subtotal ALoss from operations= has been added to the 9/30/04 financial statements
17.
The net loss from operations and net loss lines now agree
18.
The loss from sale of marketable securities is consistent throughout the financials
Statement of Cash Flows for the period through September 30, 2004
19.
The issuance of stock for marketable securities is now consistent
Summary of Significant Accounting Policies
20.
A phrase similar to >nature of business= has been included in the heading for note 1.
21.
The line item we include amounts paid to us for shipping and handling is now included
22.
The note has been revised to state that no return reserve exists due to immateriality
Exhibits
23.
The exhibits have been renumbered
Please call me if you need any further clarification on any of these answers.
Sincerely,
/s/ Thomas G. Miller
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CORRESP 1 filename1.htm SE Asia Trading Company, Inc. Correspondence Dec. 3 2004 S.E. Asia Trading Company, Inc. 1545 E. Interstate 30 Rockwall, Texas 75087 (972) 722-3300 December 2, 2004 Mr. Pradip Bhaumik Ms. Ellie Quarles Mr. H. Christopher Owings U.S. Securities & Exchange Commission 450 Fifth Street NW Washington, DC 20549 RE: S.E. Asia Trading Company, Inc. Form SB-1 File No. 333-118898 Dear Mr. Bhaumil, Ms. Quarles and Mr. Owings: Following are responses to your comment letter dated October 6, 2004. Prospectus Inside Cover Page 1. The reference to NASDAQ has been deleted and a clarification made as to when we intend to file for listing (Page 1) 2. The page reference for the APlan of Operations@ has been corrected (page 3) 3. The reference to the going concern opinion has been relocated to AOur Company@ section. And clarification made as to why that was issued (Page 2) Risk Factors 4. We have stated that the penny stock rules may adversely affect the ability of both the broker-dealers to sell the securities, etc. (page 6) Plan of Distribution 5. We have clarified that we will not cash the offering checks unless and until we raise the minimum offering (page 9) Use of Proceeds 6. The salary of Mr. Miller has been clarified (page 11) Business Strategy 7. We have clarified that we will open >one= new store during the next twelve months (page 12) Management=s Discussion and Plan of Operations Generating Sufficient Revenue 8. We have provided justification for our belief that >more and more= people are responding to our advertising (page 15) 9. We have specifically stated that we will be able to generate sufficient cash to sustain our operations (page 15) Financial Needs 10. We have amended our discussion of sales and gross profit (page 16) 11. We have provided supplementally a copy of the article on the growth in Rockwall county. Significant Parties 12. The percentage of each shareholder have been included (page 18) 13. The middle initial of Charles Smith has been inserted (page 19) Financial Statements for the Period January 28, 2004 through May 31, 2004 14. Updated financials have been included in accordance with Item 310(a) of Regulation S-B. They are nor audited per discussion with Mr. Adam Phippen Financial Statemented through September 30, 2004 Balance Sheet as of September 30, 2004 15. The total current assets figure is corrected Statement of Loss for the period through September 30, 2004 16. A description for the subtotal ALoss from operations= has been added to the 9/30/04 financial statements 17. The net loss from operations and net loss lines now agree 18. The loss from sale of marketable securities is consistent throughout the financials Statement of Cash Flows for the period through September 30, 2004 19. The issuance of stock for marketable securities is now consistent Summary of Significant Accounting Policies 20. A phrase similar to >nature of business= has been included in the heading for note 1. 21. The line item we include amounts paid to us for shipping and handling is now included 22. The note has been revised to state that no return reserve exists due to immateriality Exhibits 23. The exhibits have been renumbered Please call me if you need any further clarification on any of these answers. Sincerely, /s/ Thomas G. Miller Thomas G. Miller President