SEC Comment Letter for DUOS TECHNOLOGIES GROUP, INC. (DUOT) (CIK 0001396536) (DUOT) — Nov 19, 2007
DUOS TECHNOLOGIES GROUP, INC. (DUOT) (CIK 0001396536)
Date: Nov. 19, 2007 · CIK: 0001396536 · Accession: 0000000000-07-056518
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-142429
Referenced dates: October 12, 2007
Letter
Mail Stop 4561 November 19, 2007 Joseph P. Coschera Chief Executive Officer Information Systems Associates, Inc. 2120 SW Danforth Circle Palm City FL 34990
Re: Information Systems Associates, Inc. Amendment No. 3 to Form SB-2 Filed on November 6, 2007 File No. 333-142429
Dear Mr. Coschera:
We have reviewed your response and your amended filing and have the following comments.
General 1. Please refer to prior comment 1 of our letter dated October 12, 2007. Please update your disclosure regarding Com cast Communications for the nine-month period ended September 30, 2007. Please clarify that the consulting service agreement is for a two-year period, which began August 1, 2007. 2. Please revise your registration statement to include updated financial statements and related consents. Refer to Item 310(g) of Regulation S-B.
Financial Summary Information, page 6 3. Please revise to correct the financial summary information for the periods ended June 30, 2007 and 2006. In this regard, th e amounts on page 6 differ from your “Statements of Operations” on page 5 3. Revisions should also be made throughout your Form SB-2, including your Management’s Discussion and Analysis, to reflect the re vised interim information.
Financial Statements - June 30, 2007 and 2006
Statements of Operations, page 53
Joseph P. Coschera Information Systems Associates, Inc. November 19, 2007 Page 2
4. Please revise to provide separate earni ngs per share information for continuing operations and discontinued operatio ns. See paragraph 37 of SFAS 128.
Note 1 – Statement of Significant Accounting Policies
(j) Impairment of Long-Lived Assets, page 58 5. Your disclosures on page 58 indicate that you assess long-lived assets for impairment in accordance with SFAS 121 however your disclosures on page 69 refer to SFAS 144. Please note that SFAS 121 is no longer applicable because it was superseded by SFAS 144. Please revise your disclosures accordingly.
(l) Share-Based Payments, page 58 6. We note that your disclosures continue to re fer to the “close of market trading.” Please revise.
(m) Recent Accounting Pronouncements, page 59 7. Your disclosures on page 59 appear to i ndicate that you have not yet adopted SAB No. 108 as you disclose that SAB No. 108 “i s not expected to have a material impact.” However, we also note your di sclosure on page 72 which indicates that you adopted SAB No. 108 in the year ended December 31, 2006. Please revise accordingly.
Financial Statements – December 31, 2006 and 2005
Note A – Summary of Significant Accounting Policies
Revenue Recognition, page 68 8. Please revise your revenue recognition policy on page 68 so that it is consistent with your revised policy on page 56.
Share-Based Payments, page 70 9. As previously requested, please tell us why it was appropriate to consistently value shares issued for services at the low end of the range that you have sold your stock. In this regard, we note that the fair value of shares issued for services was $0.05 when the indicated ra nge was as high as $0.25.
You may contact Christine Davis at 202-551-3408 or Ma rk Kronforst, Accounting
Joseph P. Coschera Information Systems Associates, Inc. November 19, 2007 Page 3
Branch Chief, at 202-551-3451 if you have questions regarding comments on the financial statements and related matters. Pl ease address all other comments to me at 202- 551-3735.
S i n c e r e l y ,
B a r b a r a C . J a c o b s A s s i s t a n t D i r e c t o r
cc: Via facsimile: 772-286-3031 Information Systems Associates, Inc.
Show Raw Text
Mail Stop 4561
November 19, 2007
Joseph P. Coschera
Chief Executive Officer
Information Systems Associates, Inc.
2120 SW Danforth Circle
Palm City FL 34990
Re: Information Systems Associates, Inc.
Amendment No. 3 to Form SB-2
Filed on November 6, 2007
File No. 333-142429
Dear Mr. Coschera:
We have reviewed your response and your amended filing and have the
following comments.
General
1. Please refer to prior comment 1 of our letter dated October 12, 2007. Please update your disclosure regarding Com cast Communications for the nine-month
period ended September 30, 2007. Please clarify that the consulting service agreement is for a two-year period, which began August 1, 2007.
2. Please revise your registration statement to include updated financial statements
and related consents. Refer to Item 310(g) of Regulation S-B.
Financial Summary Information, page 6
3. Please revise to correct the financial summary information for the periods ended June 30, 2007 and 2006. In this regard, th e amounts on page 6 differ from your
“Statements of Operations” on page 5 3. Revisions should also be made
throughout your Form SB-2, including your Management’s Discussion and
Analysis, to reflect the re vised interim information.
Financial Statements - June 30, 2007 and 2006
Statements of Operations, page 53
Joseph P. Coschera
Information Systems Associates, Inc.
November 19, 2007
Page 2
4. Please revise to provide separate earni ngs per share information for continuing
operations and discontinued operatio ns. See paragraph 37 of SFAS 128.
Note 1 – Statement of Significant Accounting Policies
(j) Impairment of Long-Lived Assets, page 58
5. Your disclosures on page 58 indicate that you assess long-lived assets for
impairment in accordance with SFAS 121 however your disclosures on page 69 refer to SFAS 144. Please note that SFAS 121 is no longer applicable because it
was superseded by SFAS 144. Please revise your disclosures accordingly.
(l) Share-Based Payments, page 58
6. We note that your disclosures continue to re fer to the “close of market trading.”
Please revise.
(m) Recent Accounting Pronouncements, page 59
7. Your disclosures on page 59 appear to i ndicate that you have not yet adopted SAB
No. 108 as you disclose that SAB No. 108 “i s not expected to have a material
impact.” However, we also note your di sclosure on page 72 which indicates that
you adopted SAB No. 108 in the year ended December 31, 2006. Please revise
accordingly.
Financial Statements – December 31, 2006 and 2005
Note A – Summary of Significant Accounting Policies
Revenue Recognition, page 68
8. Please revise your revenue recognition policy on page 68 so that it is consistent
with your revised policy on page 56.
Share-Based Payments, page 70
9. As previously requested, please tell us why it was appropriate to consistently
value shares issued for services at the low end of the range that you have sold
your stock. In this regard, we note that the fair value of shares issued for services
was $0.05 when the indicated ra nge was as high as $0.25.
You may contact Christine Davis at 202-551-3408 or Ma rk Kronforst, Accounting
Joseph P. Coschera
Information Systems Associates, Inc.
November 19, 2007
Page 3
Branch Chief, at 202-551-3451 if you have questions regarding comments on the
financial statements and related matters. Pl ease address all other comments to me at 202-
551-3735.
S i n c e r e l y ,
B a r b a r a C . J a c o b s
A s s i s t a n t D i r e c t o r
cc: Via facsimile: 772-286-3031
Information Systems Associates, Inc.