SEC Company Response from Shiwana, Inc. (CIK 0001295702) — Jul 29, 2005
Shiwana, Inc. (CIK 0001295702)
Date: July 29, 2005 · CIK: 0001295702 · Accession: 0001193125-05-152531
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File numbers found in text: 333-118255
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CORRESP 1 filename1.htm Acceleration Request S H I W A N A T H E R A I N M A K E R S July 27, 2005 By Fax and Fed Ex Securities and Exchange Commission Division of Corporation Finance 450 5th Street, N.W. Washington, DC 20549 Attn: Howard M. Baik Re: Shiwana, Inc. Registration Statement on Form SB-2 File No. 333-118255 Ladies and Gentlemen: Shiwana, Inc., a Delaware corporation (the “Company”), hereby requests that the effective date of the above referenced Registration Statement, as amended by Amendment No. 5, be accelerated so that the same may become effective on Friday, July 29, 2005, or as soon thereafter as may be practicable. The Company acknowledges that, 1. should the Commission or the staff, acting pursuant to delegated authority, declare the above referenced filing effective, it does not foreclose the Commission from taking any action with respect to the filing; 2. 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 disclose in the filing; and 3. the Company may not assert staff comments and 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. There is no underwriter or dealer who is anticipated to participate in the offering of the shares to be sold pursuant to the subject registration statement. Therefore, there has been no distribution of prospectuses to any underwriter or dealer to report pursuant to Rule 460. Sincerely, SHIWANA, INC. /s/ Tim R. Sensenig Tim R. Sensenig Co-Chief Executive Officer 1320 TOWER RD · SCHAUMBURG, IL · 60173 PHONE: (487) 598-3750 · FAX: (847) 598-3710 WWW.SHIWANA.COM