SEC Comment Letter for HNO International, Inc. (HNOI) (CIK 0001342916) (HNOI) — Oct 12, 2006
HNO International, Inc. (HNOI) (CIK 0001342916)
Date: Oct. 12, 2006 · CIK: 0001342916 · Accession: 0000000000-06-049418
AI Filing Summary & Sentiment
File numbers found in text: 333-130286
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20549-4561
February 17, 2006
James B. Parsons
Parsons Law Firm
2070 Skyline Tower, 10900 NE 4th Street
Bellevue, Washington 98004
Re: American Bonanza Resources Corp.
Form SB-2, amendment number 2, filed February 13, 2006
File Number 333-130286
Dear Mr. Parsons:
We have reviewed your amended Form SB-2 and have the following comments. We
have no further accounting comments at this time. Where indicated, we think you should revise
this 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 supplemental information so we may better understand your disclosure. After reviewing this information we may have 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.
Prospectus Cover
1. Here and at the bottom of page 14, please explain what you mean by the statement that you have no desire for the warrants to trade.
General Information, page 22
2. At the first full paragraph on page 23, reconcile your statement that the information has been provided by management and the next sentence statement that you are relying upon Mr. Stephenson for the mining information in the filing.
* * * * *
American Bonanza Resources Corporation
Page 2
Closing Comments
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 supplemental 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.
Direct any questions on accounting matters to Rebekah Moore 202-551-3463, Angela
Connell, Senior Accountant at 202-551-3426. Please direct any other questions to David Lyon at 202-551-3421, or to me at 202-551-3419.
S i n c e r e l y ,
Christian Windsor
Special Counsel
By fax : James B. Parsons
Fax number 425-451-8568