SEC Company Response from Sockeye Seafood Group Inc (CIK 0001301557) — Dec 22, 2005
Sockeye Seafood Group Inc (CIK 0001301557)
Date: Dec. 22, 2005 · CIK: 0001301557 · Accession: 0001093287-05-000193
AI Filing Summary & Sentiment
File numbers found in text: 000-51197
Letter
SOCKEYE SEAFOOD GROUP, INC. December 19, 2005 Blaise A. Rhodes Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street N.E. Mail Stop 3561 Washington, D.C. 20549
RE: Sockeye Seafood Group, Inc. Item 4.01 Form 8-K File Number 000-51197
Dear Mr. Rhodes:
In response to your letter of November 25, 2005, I herewith respectfully submit the following responses, keyed to correspond to your enumerated comments:
1. We concluded that it was appropriate to hire an audit firm based in Malaysia for the following reasons: Our previous audit firm, Franklin Griffith and Associates, deregistered with the PCAOB and we found we needed to engage a new audit firm. Since David Knapfel, our Treasurer and Chief Financial Officer, now lives near Kuala Lumpur, Malaysia full time, we found it easier for him to communicate with an auditor located in the same city and with whom he had a prior working relationship. Furthermore, with Mr. Knapfel now living in Malaysia we are intending to expand operations into Malaysia and SE Asia which would increase the relevance of having our auditor there.
2. The audit firm of Esther Yap & Co. has been preparing financial reports for inclusion with SEC filings since April 2004. Mr. Knapfel was also a director of Thai One On, Inc., a publicly-traded company located in Malaysia, which used the audit firm of Esther Yap & Co. Audits and financial statements reviewed by the audit firm of Esther Yap & Co. were fully reviewed by the accounting staff at the SEC during the review process of Thai One On's SB-2 registration statement and associated amended filings and found to be satisfactory. We were therefore under the impression that their knowledge and expertise had already been demonstrated to the SEC satisfactorily over the past year and a half that they have been auditing and reviewing statements for SEC filings. We were also under the impression that during registration with the PCAOB, they also had to demonstrate some of these abilities in order to have their registration with the PCAOB granted.
Please find attached the requested letter of acknowledgement. We also filed the same letter on May 25, 2005 as was requested by the staff of the SEC at that time.
Thank you very much for your kind cooperation and assistance in this matter. If you have any further questions you can leave a message for me at our office or contact me via email at fish@sockeyeseafood.com.
Very truly yours,
/s/ David Knapfel,
Treasurer and CFO
Show Raw Text
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SOCKEYE SEAFOOD GROUP, INC.
December 19, 2005
Blaise A. Rhodes
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street N.E.
Mail Stop 3561
Washington, D.C. 20549
RE: Sockeye Seafood Group, Inc.
Item 4.01 Form 8-K
File Number 000-51197
Dear Mr. Rhodes:
In response to your letter of November 25, 2005, I herewith respectfully
submit the following responses, keyed to correspond to your enumerated
comments:
1. We concluded that it was appropriate to hire an audit firm based
in Malaysia for the following reasons: Our previous audit firm, Franklin
Griffith and Associates, deregistered with the PCAOB and we found we
needed to engage a new audit firm. Since David Knapfel, our Treasurer and
Chief Financial Officer, now lives near Kuala Lumpur, Malaysia full time,
we found it easier for him to communicate with an auditor located in the
same city and with whom he had a prior working relationship. Furthermore,
with Mr. Knapfel now living in Malaysia we are intending to expand
operations into Malaysia and SE Asia which would increase the relevance
of having our auditor there.
2. The audit firm of Esther Yap & Co. has been preparing financial reports
for inclusion with SEC filings since April 2004. Mr. Knapfel was also a
director of Thai One On, Inc., a publicly-traded company located in Malaysia,
which used the audit firm of Esther Yap & Co. Audits and financial
statements reviewed by the audit firm of Esther Yap & Co. were fully
reviewed by the accounting staff at the SEC during the review process of
Thai One On's SB-2 registration statement and associated amended filings
and found to be satisfactory. We were therefore under the impression that
their knowledge and expertise had already been demonstrated to the SEC
satisfactorily over the past year and a half that they have been auditing
and reviewing statements for SEC filings. We were also under the impression
that during registration with the PCAOB, they also had to demonstrate
some of these abilities in order to have their registration with the PCAOB
granted.
Please find attached the requested letter of acknowledgement. We also filed
the same letter on May 25, 2005 as was requested by the staff of the SEC at
that time.
Thank you very much for your kind cooperation and assistance in this matter.
If you have any further questions you can leave a message for me at our
office or contact me via email at fish@sockeyeseafood.com.
Very truly yours,
/s/ David Knapfel,
Treasurer and CFO
400-601 West Broadway
Vancouver BC V5Z 4C2 CANADA
Phone: 604-675-6872
Fax: 604-713-8601
Email: fish@sockeyeseafood.com
http://www.sockeyeseafood.com
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