SEC Comment Letter for China Teletech Holding Inc (CNCT) (CIK 0001346287) (CLUS) — Apr 9, 2007
China Teletech Holding Inc (CNCT) (CIK 0001346287)
Date: April 9, 2007 · CIK: 0001346287 · Accession: 0000000000-07-017336
AI Filing Summary & Sentiment
File numbers found in text: 333-130937
Letter
Via Facsimile and U.S. Mail Mail Stop 6010 A p r i l 9 , 2 0 0 7 Li Yankuan President Guangzhou Global Telecom, Inc. Room 1802, North Tower, Suntec Plaza No. 197 Guangzhou Avenue North Guangzhou, PRC 510075
Re: Guangzhou Global Telecom, Inc. Item 4.01 Form 8-K Filed April 6, 2007 File No. 333-130937
Dear Mr. Yankuan:
We have reviewed your filing and have the following comments. Where indicated, we think you should re vise 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. Pleas e be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view 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 any other aspect of our review. Feel free to call us at the telephone number listed at the end of this letter.
Item 4.01(a)
1. Please revise paragraph (iii ) to state whether during th e registrant’s two most recent fiscal years and any subsequent interim period preceding dismissal there were any disagreements with the former accountant. You should specify the “subsequent interim period” as the “i nterim period through April 4, 2007”.
2. To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an upda ted Exhibit 16 letter from the former
Li Yankuan Guangzhou Global Telecom, Inc. April 9, 2007 Page 2 accountant stating whether the accountant ag rees with the statements made in your revised Form 8-K.
As appropriate, please amend your fili ng and respond to these comments within five business days or tell us when you will re spond. 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 comm ents after reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments 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.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
If you have any questions, pl ease call me at (202) 551-3649.
S i n c e r e l y ,
Vanessa Robertson S t a f f A c c o u n t a n t
Show Raw Text
Via Facsimile and U.S. Mail
Mail Stop 6010
A p r i l 9 , 2 0 0 7
Li Yankuan
President
Guangzhou Global Telecom, Inc.
Room 1802, North Tower, Suntec Plaza
No. 197 Guangzhou Avenue North
Guangzhou, PRC 510075
Re: Guangzhou Global Telecom, Inc.
Item 4.01 Form 8-K
Filed April 6, 2007
File No. 333-130937
Dear Mr. Yankuan:
We have reviewed your filing and have the following comments. Where
indicated, we think you should re vise 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. Pleas e be as detailed as necessary in your explanation. After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view 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 any other aspect of our
review. Feel free to call us at the telephone number listed at the end of this letter.
Item 4.01(a)
1. Please revise paragraph (iii ) to state whether during th e registrant’s two most
recent fiscal years and any subsequent interim period preceding dismissal there
were any disagreements with the former accountant. You should specify the “subsequent interim period” as the “i nterim period through April 4, 2007”.
2. To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an upda ted Exhibit 16 letter from the former
Li Yankuan
Guangzhou Global Telecom, Inc.
April 9, 2007 Page 2
accountant stating whether the accountant ag rees with the statements made in
your revised Form 8-K.
As appropriate, please amend your fili ng and respond to these comments within
five business days or tell us when you will re spond. 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 comm ents after reviewing your amendment and
responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments 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.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
If you have any questions, pl ease call me at (202) 551-3649.
S i n c e r e l y ,
Vanessa Robertson
S t a f f A c c o u n t a n t