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SEC Comment Letter for VIKA CORP. (CIK 0001309710) — Nov 2, 2005

VIKA CORP. (CIK 0001309710)
Date: Nov. 2, 2005 · CIK: 0001309710 · Accession: 0000000000-05-055821

AI Filing Summary & Sentiment

File numbers found in text: 333-124421

Referenced dates: August 9, 2005, August 9, 2005

Date
October 6, 2005
Author
Assistant Director
Form
UPLOAD
Company
VIKA CORP. (CIK 0001309710)

Letter

Mail Stop 3561 October 6, 2005 Scott Sutherland President Vika Corp. Suite 202, 2310 W 2nd Ave. Vancouver, BC V6K 1J1

Re: Vika Corp. Amendment No. 2 to Registration Statement on Form SB-2 File No. 333-124421 Filed September 16, 2005

Dear Mr. Sutherland:

We have reviewed your filing and have the following comments Where indicated, we think you should revise your document in response to these comments If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. Please feel free to call us at the telephone numbers listed at the end of this letter.

Determination of Offering Price, page 7 1. We note your response to comment 3 in our letter dated August 9, 2005. Please include your response in the next amendment to your filing.

Plan of Operation, page 21 2. We note your revisions in response to comment 9 in our letter dated August 9, 2005. Based on your revenues as of the most recent practicable date and the uncertainty of additional funding, please state how long you realistically expect to continue as a viable business.

Legality Opinion, Exhibit 5.1 3. The disclaimer in the last paragraph of your legality opinion is inappropriate. Please delete. Also, your legality opinion must be dated as of the effective date of your filing. *****

As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to

expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

You may contact Milwood Hobbs, Staff Accountant, at (202) 551- 3241 or Michael Moran, Senior Staff Accountant, at (202) 551-3841, if you have questions regarding comments on the financial statements and related matters. Please contact Anita Karu, Attorney-Advisor, at (202) 551-3240, Eloise Quarles, Special Counsel, at (202) 551- 3238, or me at (202) 551-3720 with any other questions.

Sincerely,
H. Christopher Owings
Assistant Director

Show Raw Text
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<TEXT>

Mail Stop 3561
								October 6, 2005

Scott Sutherland
President
Vika Corp.
Suite 202, 2310 W 2nd Ave.
Vancouver, BC V6K 1J1

Re:	  Vika Corp.
        Amendment No. 2 to Registration Statement on Form SB-2
        File No. 333-124421
        Filed September 16, 2005

Dear Mr. Sutherland:

      We have reviewed your filing and have the following comments
Where indicated, we think you should revise your document in
response
to these comments  If you disagree, we will consider your
explanation
as to why our comments are inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  Please
feel
free to call us at the telephone numbers listed at the end of this
letter.

Determination of Offering Price, page 7
1. We note your response to comment 3 in our letter dated August
9,
2005.  Please include your response in the next amendment to your
filing.

Plan of Operation, page 21
2. We note your revisions in response to comment 9 in our letter
dated
August 9, 2005.  Based on your revenues as of the most recent
practicable date and the uncertainty of additional funding, please
state how long you realistically expect to continue as a viable
business.

Legality Opinion, Exhibit 5.1
3. The disclaimer in the last paragraph of your legality opinion
is
inappropriate.  Please delete.  Also, your legality opinion must
be
dated as of the effective date of your filing.
*****

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to

expedite our review.  Please furnish a cover letter with your
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

      You may contact Milwood Hobbs, Staff Accountant, at (202)
551-
3241 or Michael Moran, Senior Staff Accountant, at (202) 551-3841,
if
you have questions regarding comments on the financial statements
and
related matters.  Please contact Anita Karu, Attorney-Advisor, at
(202) 551-3240, Eloise Quarles, Special Counsel, at (202) 551-
3238, or
me at (202) 551-3720 with any other questions.

      Sincerely,

      H. Christopher Owings
      Assistant Director

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Scott Sutherland, President
Vika Corp.
October 6, 2005
Page 1

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