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SEC Comment Letter for RAADR, INC. (RDAR) (CIK 0001384365) (RDAR) — Mar 26, 2014

RAADR, INC. (RDAR) (CIK 0001384365)
Date: March 26, 2014 · CIK: 0001384365 · Accession: 0000000000-14-015228

AI Filing Summary & Sentiment

File numbers found in text: 000-53991

Date
March 26, 2014
Author
/s/ Myra Moosariparambil
Form
UPLOAD
Company
RAADR, INC. (RDAR) (CIK 0001384365)

Letter

March 26 , 2014 Via E-mail Jacob DiMartino Chief Executive Officer Pitooey! , Inc. 15685 N. Cave Creek Rd . Suite 101 Scottsdale, AZ 85032

Re: Pitooey! , Inc. Form 8 -K Filed March 25 , 2014 File No. 000-53991

Dear Mr. DiMartino :

We have reviewed your filing an d have the following comment s. 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 five busines s days by amending your filing or by advising us when you will provide the requested response. If you do not believe our comment s apply to your facts and circumstances or do not belie ve an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.

Form 8 -K filed March 25 , 2014

1. Please amend your form 8 -K to include the following:

 A statement whether the former accountant resigned, declined to stand for re -election or was dismissed and the date thereof, as required by Item 304(a)(1)(i) of Regulation S-K;

 A statement whether the change of accountant was recommended or approved by any audit or similar committee of the board of directors or the board of directors, if you have no audit or similar committee. Refer to Item 3 04(a)(1)(iii) of Regulation S -K;

Jacob DiMartino Pitooey! , Inc. March 26 , 2014 Page 2

 A statement whether your former accountant's report on the financial statements for either of the past two years contained an adverse opinion or a disclaimer of opinion or was qualified or modified as to uncertainty, audit scope or accounting principles; and a description of the nature of each such adverse opinion, disclaim er of opinion, modification or qualification. Refer to Item 304(a)(1)(ii) of Regulation S -K;

 A statement whether there were any disagreements with your former accountant during the two most recent fiscal years and any subsequent interim period through th e date of resignation, declination or dismissal of your former accountant. Refer to Item 304(a)(1)(iv) of Regulation S -K;

 In the event of disagreement(s) and/or reportable event(s), provide the specific disclosures required by Item 304(a)(1)(iv) and (v) of Regulation S -K;

 A statement whether during your two most recent fiscal years, and any subsequent period pri or to engaging your new accountant you consulted the new accountant regarding any matters identified in Item 304(a)(2) of Regulation S -K.

2. In your amendment please also include a letter, as an Exhibit 16, from your former accountant addressing to the Commission to state whether it agrees with the statements made by you in response to the required disclosure under Item 304(a) of Regulation S -K and if not, states the respects in which it does not agree. Refer to Item 304(a)(3) of Regulation S -K.

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 the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. 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 di sclosures they have made.

In responding to our comments, please provide a written 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 fe deral securities laws of the United States.

Jacob DiMartino Pitooey! , Inc. March 26 , 2014 Page 3

If you have questions regarding these comments and related matters , please contact me at 202-551-3796 .

Sincerely,
/s/ Myra Moosariparambil

Show Raw Text
March 26 , 2014

Via E-mail
Jacob DiMartino
Chief Executive Officer
Pitooey! , Inc.
15685  N. Cave Creek Rd .
Suite 101
Scottsdale, AZ 85032

Re: Pitooey! , Inc.
 Form 8 -K
Filed March 25 , 2014
File No. 000-53991

Dear Mr. DiMartino :

We have reviewed your filing an d have the following comment s.  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 five busines s days by amending your filing or by
advising us when you will provide the requested response.   If you do not believe our comment s
apply  to your facts and circumstances or do not belie ve an amendment is appropriate, please tell
us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 8 -K filed March 25 , 2014

1.  Please amend your form 8 -K to include the following:

 A statement whether the former accountant resigned, declined to stand for re -election
or was dismissed and the date thereof, as required by Item 304(a)(1)(i) of Regulation
S-K;

 A statement whether the change of accountant was recommended or approved by any
audit or similar committee of the board of directors or the board of directors, if you
have no audit or similar committee. Refer to Item 3 04(a)(1)(iii) of Regulation S -K;

Jacob DiMartino
Pitooey! , Inc.
March 26 , 2014
Page 2

  A statement whether your former accountant's report on the financial statements for
either of the past two years contained an adverse opinion or a disclaimer of opinion or
was qualified or modified as to uncertainty, audit scope or accounting principles; and
a description of the nature of each such adverse opinion, disclaim er of opinion,
modification or qualification.  Refer to Item 304(a)(1)(ii) of Regulation S -K;

 A statement whether there were any disagreements with your former accountant
during the two most recent fiscal years and any subsequent interim period through th e
date of resignation, declination or dismissal of your former accountant.  Refer to Item
304(a)(1)(iv) of Regulation S -K;

 In the event of disagreement(s) and/or reportable event(s), provide the specific
disclosures required by Item 304(a)(1)(iv) and (v) of Regulation S -K;

 A statement whether  during your two most recent fiscal years, and any subsequent
period pri or to engaging your new accountant you consulted the new accountant
regarding any matters identified in Item 304(a)(2) of Regulation S -K.

2.  In your amendment please also include a letter, as an Exhibit 16, from your former
accountant addressing to the Commission to state whether it agrees with the statements
made by you in  response to the required disclosure under Item 304(a)  of Regulation S -K
and if not, states the respects in which it does not agree.  Refer to Item 304(a)(3) of
Regulation S -K.

 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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 di sclosures they have made.

 In responding to our comments, please provide  a written 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 fe deral securities laws of the United
States.

Jacob DiMartino
Pitooey! , Inc.
March 26 , 2014
Page 3

 If you have questions regarding these comments and related matters , please contact me at
202-551-3796 .

Sincerely,

 /s/ Myra Moosariparambil

Myra Moosariparambil
Staff Accountant