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SEC Company Response from Chartwell International, Inc. (CIK 0001329184) — Jun 13, 2005

Chartwell International, Inc. (CIK 0001329184)
Date: June 13, 2005 · CIK: 0001329184 · Accession: 0001001277-05-000396

AI Filing Summary & Sentiment

Date
June 13, 2005
Author
Sara M. Dayton
Form
CORRESP
Company
Chartwell International, Inc. (CIK 0001329184)

Letter

June 13, 2005 Via Edgar Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, NW, Mail Stop 0409 Washington, D.C. 20549-0303 Attn: Michael McTiernan, Special Counsel

Re: Chartwell International, Inc. Form 10SB-12G- Filed on June 3, 2005 and Form 10SB-12G/A-1 - Filed on June 13, 2005 Registration No. 051342

Dear Mr. McTiernan:

In connection with Chartwell International, Inc.'s (the "Company's") Form 10SB, the Company is filing an amendment to Form 10SB in response to the staff's June 9, 2005 comment letter.

Financial statements reflecting the spin-off of Kingsley and the subsequent sale of common stock was added under Part F/S. The following unaudited financial statements for the quarter ending April 30, 2005 were added: (i) Condensed Consolidated Balance Sheets as of April 30, 2005 and July 31, 2004; (ii) Condensed Consolidated Statements of Operations for the Three and Nine-Month Periods Ended April 30, 2005 and 2004; (iii) Condensed Consolidated Statements of Cash Flows for the Three and Nine-Month Periods Ended April 30, 2005 and 2004; and (iv) Notes to Condensed Consolidated Financial Statements. Under Item 2., Management's Discussion and Analysis or Plan of Operation, additional disclosure regarding the Company's financial condition as of April 30, 2005 was added.

With the filing of the amended Form 10-SB, we believe that the Company has fully responded to the staff's comment letter. Should the staff have additional questions or need additional information, please do not hesitate to contact Daniel Eng or the undersigned at (916) 442-0400.

Very truly yours,
/s/ Sara M. Dayton
Sara M. Dayton

Show Raw Text
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<TEXT>

SARA M. DAYTON
e-mail:  sdayton@barteleng.com

                                  June 13, 2005

Via Edgar

Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, NW, Mail Stop 0409
Washington, D.C.  20549-0303
Attn:  Michael McTiernan, Special Counsel

         Re:      Chartwell International, Inc.
                  Form 10SB-12G- Filed on June 3, 2005 and
                  Form 10SB-12G/A-1 - Filed on June 13, 2005
                  Registration No. 051342

Dear Mr. McTiernan:

     In connection with Chartwell  International,  Inc.'s (the "Company's") Form
10SB, the Company is filing an amendment to Form 10SB in response to the staff's
June 9, 2005 comment letter.

     Financial statements reflecting the spin-off of Kingsley and the subsequent
sale of common stock was added under Part F/S. The following unaudited financial
statements  for the quarter  ending  April 30, 2005 were  added:  (i)  Condensed
Consolidated  Balance  Sheets  as of April  30,  2005 and  July 31,  2004;  (ii)
Condensed  Consolidated  Statements of Operations  for the Three and  Nine-Month
Periods Ended April 30, 2005 and 2004; (iii) Condensed  Consolidated  Statements
of Cash Flows for the Three and  Nine-Month  Periods  Ended  April 30,  2005 and
2004; and (iv) Notes to Condensed Consolidated Financial Statements.  Under Item
2.,  Management's  Discussion  and  Analysis  or Plan of  Operation,  additional
disclosure  regarding the Company's financial condition as of April 30, 2005 was
added.

     With the filing of the amended Form 10-SB,  we believe that the Company has
fully responded to the staff's comment letter.  Should the staff have additional
questions  or need  additional  information,  please do not  hesitate to contact
Daniel Eng or the undersigned at (916) 442-0400.

                                Very truly yours,

                                /s/ Sara M. Dayton
                                Sara M. Dayton

SMD/cea

cc:      Dr. Janice Jones
         Imre Eszenyi

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