SEC Comment Letter for Stratos Renewables Corp (SRNW) (CIK 0001321517) — Jul 13, 2005
Stratos Renewables Corp (SRNW) (CIK 0001321517)
Date: July 13, 2005 · CIK: 0001321517 · Accession: 0000000000-05-035810
AI Filing Summary & Sentiment
File numbers found in text: 333-124060
Referenced dates: May 11, 2005, May 11, 2005
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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Mail Stop 3561 July 11, 2005
Kenneth P. Laurent c/o
Savoy Financial Group
6767W. Tropicana Ave., Suite 207
Las Vegas, NV 89103
Re: New Design Cabinets, Inc.
Amendment No. 1 to Registration Statement on Form SB-2
File No. 333-124060
Filed June 22, 2005
Dear Mr. Laurent:
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 comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation. In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure. After reviewing this
information,
we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We
look forward to working with you in these respects. We welcome
any
questions you may have about our comments or on any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Inside Front Cover Page of Prospectus
1. Please include the dealer prospectus delivery obligation
described
in Item 502(b) of Regulation S-B.
Plan of Distribution, page 10
2. We reissue comment 14 in our letter dated May 11, 2005, as it
appears that you did not revise your disclosure. In this regard,
please be aware that your response did not fully address comment
14.
Interest of Named Experts and Counsel, page 12
3. We have reviewed your response to comment 17 in our letter
dated
May 11, 2005. Please revise your filing to include an "Experts"
section which discusses the involvement of all experts associated
with
your filing, including your auditors and legal counsel. In
addition,
please have your experts revise their consents to consent to your
references to them as experts. See Rule 436 of Regulation C.
Please
also ensure you update the table of contents, as appropriate.
Managements` Discussion and Plan of Operations, page 16
4. We note your response to comment 1 in our letter dated May 11,
2005. You state that you are not a blank check company as defined
in
Rule 419, but rather a development stage company that has not
commenced planned principal operations. You state in your revised
disclosure that you will need to generate a minimum of $18,000 in
the
next twelve months in order to maintain your current level of
operations. Please describe in further detail how you will do
this.
In addition, revise to more fully and specifically set forth your
plan
of operation in a manner consistent with Item 303(a) of Regulation
S-
B.
Note 1 - Nature of Business, page F6
5. We have reviewed your response to comment 33 in our letter
dated
May 11, 2005, noting that you still disclose that your customers
and
manufactured products are your most important assets. Please
revise
your footnote to clarify that you currently do not have any
customers
and have not manufactured any products.
***
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 Andrew Blume, Staff Accountant, at (202)
551-
3254 or George Ohsiek, Senior Staff Accountant, at (202) 551-3843,
if
you have questions regarding comments on the financial statements
and
related matters. Please contact Anita Karu, Attorney-Advisor, at
(202) 551-3240, or me at (202) 551-3725 with any other questions.
Sincerely,
H. Christopher Owings
Assistant Director
cc: Wendy E. Miller, Esq.
Fax: (949) 625-8885
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Kenneth P. Laurent
New Design Cabinets, Inc.
July 11, 2005
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