SEC Company Response from Chartwell International, Inc. (CIK 0001329184) — Jun 20, 2005
Chartwell International, Inc. (CIK 0001329184)
Date: June 20, 2005 · CIK: 0001329184 · Accession: 0001001277-05-000410
AI Filing Summary & Sentiment
Letter
June 20, 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; Form 10SB-12G/A-1 - Filed on June 13, 2005 and Form 10SB-12G/A-2 - Filed on June 20, 2005 Registration No. 051342
Dear Mr. McTiernan:
Chartwell International, Inc. (the "Company") is filing an Amendment No. 2 to Form 10SB in response to the staff's June 15, 2005 comment letter. The item numbers refer to the item numbers in the staff's comment letter.
1. The Company considered the staff's comment and revised the disclosure accordingly. The disclosure regarding the spin-off and the potential section 5 violation was revised to remove the reference to compliance with Staff Legal Bulletin No. 4. The revised disclosure states that there may be a Section 5 violation and identifies the potential consequences of such violation.
2. The Company reviewed the background descriptions of its officers and directors and revised in accordance with the staff's comment. The background descriptions of the officers and directors were revised adding additional information regarding dates to clarify to the reader that the descriptions include each person's business experience during the past five years.
The Company has been advised that it is responsible for the adequacy and accuracy of the disclosure in the filing; that staff comments or changes to disclosure in response to staff's comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
With the filing of the Amendment No. 2 to 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 David C. Adams or the undersigned at (916) 442-0400.
Very truly yours,
/s/ Sara M. Dayton
Sara M. Dayton, Esq.
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SARA M. DAYTON
e-mail: sdayton@barteleng.com
June 20, 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; Form 10SB-12G/A-1 -
Filed on June 13, 2005 and Form 10SB-12G/A-2 - Filed on June
20, 2005 Registration No. 051342
Dear Mr. McTiernan:
Chartwell International, Inc. (the "Company") is filing an Amendment No. 2
to Form 10SB in response to the staff's June 15, 2005 comment letter. The item
numbers refer to the item numbers in the staff's comment letter.
1. The Company considered the staff's comment and revised the disclosure
accordingly. The disclosure regarding the spin-off and the potential
section 5 violation was revised to remove the reference to compliance
with Staff Legal Bulletin No. 4. The revised disclosure states that
there may be a Section 5 violation and identifies the potential
consequences of such violation.
2. The Company reviewed the background descriptions of its officers and
directors and revised in accordance with the staff's comment. The
background descriptions of the officers and directors were revised
adding additional information regarding dates to clarify to the reader
that the descriptions include each person's business experience during
the past five years.
The Company has been advised that it is responsible for the adequacy
and accuracy of the disclosure in the filing; that staff comments or
changes to disclosure in response to staff's comments in the filings
reviewed by the staff do not foreclose the Commission from taking any
action with respect to the filing; and the Company may not assert staff
comments as a defense in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.
With the filing of the Amendment No. 2 to 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 David C. Adams or the undersigned at (916) 442-0400.
Very truly yours,
/s/ Sara M. Dayton
Sara M. Dayton, Esq.
SMD/cea
cc: Dr. Janice Jones
Imre Eszenyi
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