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SEC Comment Letter for PANOSHAN (CIK 0001301369) — May 11, 2005

PANOSHAN (CIK 0001301369)
Date: May 11, 2005 · CIK: 0001301369 · Accession: 0000000000-05-023165

AI Filing Summary & Sentiment

File numbers found in text: 333-118576

Date
May 3, 2005
Author
Elaine Wolff
Form
UPLOAD
Company
PANOSHAN (CIK 0001301369)

Letter

May 3, 2005 Jonathan Levine President Panoshan Marketing Corp. Suite 400, 715-5th Avenue S.W. Calgary, Alberta, T2P 2X6, Canada

Re: Panoshan Marketing Corp. Amendment No. 5 to Registration Statement on Form F-1 Registration No. 333-118576 Filed April 28, 2005

Dear Mr. Levine:

This is to advise you that a preliminary review of the above registration statement indicates material deficiencies of the requirements of the Securities Act of 1933, and the rules and regulations under the Act. For example, we note that you have not included consolidated interim financial statements covering at least the first six months of the current financial year in accordance with Item 8.A.5. of Form 20-F. For this reason, we will not perform a detailed examination of the registration statement and we will not issue comments because to do so would delay the review of other disclosure documents that do not appear to contain comparable deficiencies.

We suggest that you consider submitting an amendment that includes updated financial statements. We will commence our review of your registration statement at that time. Please refer any questions to Owen Pinkerton, Attorney-Adviser, at (202) 551-3694.

Sincerely,
Elaine Wolff
Branch Chief

Show Raw Text
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<TEXT>

May 3, 2005

Jonathan Levine
President
Panoshan Marketing Corp.
Suite 400, 715-5th Avenue S.W.
Calgary, Alberta, T2P 2X6, Canada

Re:	Panoshan Marketing Corp.
	Amendment No. 5 to Registration Statement on Form F-1
	Registration No. 333-118576
	Filed April 28, 2005

Dear Mr. Levine:

	This is to advise you that a preliminary review of the above
registration statement indicates material deficiencies of the
requirements of the Securities Act of 1933, and the rules and
regulations under the Act.  For example, we note that you have not
included consolidated interim financial statements covering at
least
the first six months of the current financial year in accordance
with
Item 8.A.5. of Form 20-F.  For this reason, we will not perform a
detailed examination of the registration statement and we will not
issue comments because to do so would delay the review of other
disclosure documents that do not appear to contain comparable
deficiencies.

	We suggest that you consider submitting an amendment that
includes updated financial statements.  We will commence our
review
of your registration statement at that time.   Please refer any
questions to Owen Pinkerton, Attorney-Adviser, at (202) 551-3694.

							Sincerely,

							Elaine Wolff
							Branch Chief

cc:	W. Scott Lawlor, Esq. (via facsimile)

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