SEC Company Response from Fortune Partners, Inc. (CIK 0001310261) — Apr 21, 2005
Fortune Partners, Inc. (CIK 0001310261)
Date: April 21, 2005 · CIK: 0001310261 · Accession: 0001127855-05-000284
AI Filing Summary & Sentiment
File numbers found in text: 333-120951
Letter
Via EDGAR and facsimile (1-(202) 942-9516) ------------------------------------------ April 21, 2005 SECURITIES AND EXCHANGE COMMISSION ---------------------------------- 450 Fifth Street, N.W. Washington, D.C. U.S.A., 20549-0405 Attention: Mr. John Reynolds, Assistant Director Office of Emerging Growth Companies -------------------------------------------------------
Dear Mr. Reynolds:
Re: Fortune Partners, Inc. (the "Company") -------------------------------------- Registration Statement on Form SB-2- File No. 333-120951 --------------------------------------------------------
ACCELERATION REQUEST FOR REGISTRATION STATEMENT -----------------------------------------------
Fortune Partners, Inc., as the registrant of the above-captioned registration statement, hereby respectfully requests that the registration statement be permitted to become effective at 12:00 p.m. (noon), Washington, D.C. time, on Friday, April 22, 2005, or as soon thereafter as is practicable. Please advise our corporate counsel, Thomas J. Deutsch, of Devlin Jensen, Barristers & Solicitors, at (604) 684-2550, of any questions you may have respecting this request.
In connection with our request for acceleration we confirm that:
(a) we are aware of our responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in our registration statement;
(b) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
(c) 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 disclosure in the filing; and
<PAGE>
(d) the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
FORTUNE PARTNERS, INC.
----------------------
Per:
"Donald M. Prest"
Donald M. Prest
Secretary, Treasurer, Principal Accounting Officer and Principal Financial
Officer
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FORTUNE PARTNERS, INC.
----------------------
Suite 1100, 1050 West Pender Street
Vancouver, British Columbia, Canada, V6E 3S7
Telephone: (604) 714-3663 and Fax: (604) 714-3669
--------------------------------------
Via EDGAR and facsimile (1-(202) 942-9516)
------------------------------------------
April 21, 2005
SECURITIES AND EXCHANGE COMMISSION
----------------------------------
450 Fifth Street, N.W.
Washington, D.C.
U.S.A., 20549-0405
Attention: Mr. John Reynolds, Assistant Director
Office of Emerging Growth Companies
-------------------------------------------------------
Dear Mr. Reynolds:
Re: Fortune Partners, Inc. (the "Company")
--------------------------------------
Registration Statement on Form SB-2- File No. 333-120951
--------------------------------------------------------
ACCELERATION REQUEST FOR REGISTRATION STATEMENT
-----------------------------------------------
Fortune Partners, Inc., as the registrant of the above-captioned
registration statement, hereby respectfully requests that the registration
statement be permitted to become effective at 12:00 p.m. (noon), Washington,
D.C. time, on Friday, April 22, 2005, or as soon thereafter as is practicable.
Please advise our corporate counsel, Thomas J. Deutsch, of Devlin Jensen,
Barristers & Solicitors, at (604) 684-2550, of any questions you may have
respecting this request.
In connection with our request for acceleration we confirm that:
(a) we are aware of our responsibilities under the Securities Act of 1933
and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in our registration
statement;
(b) should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
(c) 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 disclosure in the filing; and
<PAGE>
(d) the Company may not assert this action as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
Very truly yours,
FORTUNE PARTNERS, INC.
----------------------
Per:
"Donald M. Prest"
Donald M. Prest
Secretary, Treasurer, Principal Accounting Officer and Principal Financial
Officer
fc: S. Thomas Kluck II, Division of Corporation Finance
Via Fax (202) 942-9516
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