SEC Comment Letter for Lexaria Bioscience Corp. (LEXX) (CIK 0001348362) (LEXX) — Mar 12, 2012
Lexaria Bioscience Corp. (LEXX) (CIK 0001348362)
Date: March 12, 2012 · CIK: 0001348362 · Accession: 0000000000-12-012520
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March 12, 2012
Via E-mail
Bal Bhullar, Chief Financial Officer Lexaria Corp. 950-1130 West Pender Street Vancouver, BC V6E 4A4 Canada
Re: Lexaria Corp.
Form 10-K for Fiscal Year Ended October 31, 2011
Filed January 30, 2012 File No. 0-52138
Dear Ms. Bhullar:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
Form 10-K for Fiscal Year Ended October 31, 2011
Report of Independent Regist ered Public Accounting Firm
1. We note the audit report of MNP LLP references and relies on the audit opinion of other
auditors dated January 21, 2011 relating to the fi nancial statements as of and for the year
ended October 31, 2010 and for the cumulativ e data from November 1, 2009 through
October 31, 2010. Please amend your filing to present the audit opinion issued by your
prior auditor in this Form 10-K as of October 31, 2011.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Bal Bhullar Lexaria Corp. March 12, 2012 Page 2
In responding to our comments, please provi de a written statement from the company
acknowledging that:
the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of the United States.
You may contact Sandy Eisen at (202) 551-3864 or Shannon Buskirk at (202) 551-3717
if you have questions regarding comments on the financial statements and related matters.
Please contact me at (202) 551-3311 with any other questions.
Sincerely,
/s/ Ethan Horowitz
Ethan Horowitz Branch Chief