SEC Company Response from Iveda Solutions, Inc. (IVDA, IVDAW) (CIK 0001397183) (IVDA) — Feb 6, 2012
Iveda Solutions, Inc. (IVDA, IVDAW) (CIK 0001397183)
Date: Feb. 6, 2012 · CIK: 0001397183 · Accession: 0001144204-12-005888
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 23, 2012
Letter
United States Securities and Exchange Commission April 30, 2011 Form 8-K/A Filed July 15, 2011 June 30, 2011 Form 10-Q Filed August 15, 2011 September 30, 2011 Form 10-Q Filed November 14, 2011
Re: Iveda Solutions, Inc. File No. 0-53285
Dear Mr. O’Brien:
Iveda Solutions, Inc. (the “Company”) hereby submits this response to the letter dated January 23, 2012 (the “January Comment Letter”) of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the above-referenced filings.
As discussed with Al Pavot of the Staff on February 2, 2012, the Company respectfully requests an extension of time to respond to the Commission’s comments. The Company expects to be in a position to provide its response no later than April 3, 2012.
The Company has entered into a new engagement with the Strategic Equity Group, an independent valuation firm hired by the Company in connection with the acquisition of Sole-Vision Technologies, Inc. (“MegaSys”), to perform impairment testing of goodwill carried on the Company’s financial statements and evaluate the status of the original purchase allocation. The Company is evaluating whether there will be a material change in our goodwill valuation based on the operating results of MegaSys in the year ended December 31, 2011. In addition, the Company is currently engaged with its annual audit and our auditors will be testing the original purchase price allocation and any updated impairment results.
With respect to your request in comment 3 in your January 23, 2012 letter, the Company will amend the Form 10-K filed on March 30, 2011 to include the Disclosure Schedule to the Share Exchange Agreement no later than February 8, 2012.
If the Staff is in agreement with this request for additional time to respond, the Company will provide a comprehensive response to the January Comment Letter on or before April 3, 2012.
Thank you for your consideration of this request.
Sincerely yours,
/s/ Lynne Phillis
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[Iveda Letterhead]
February 3, 2012
United States Securities and Exchange Commission
Terence O’Brien, Accounting Branch Chief
Washington D.C. 20549
Re:
Iveda Solutions, Inc. File No. 0-53285
April 30, 2011 Form 8-K/A Filed July 15, 2011
June 30, 2011 Form 10-Q Filed August 15, 2011
September 30, 2011 Form 10-Q Filed November 14, 2011
Dear Mr. O’Brien:
Iveda Solutions, Inc. (the “Company”)
hereby submits this response to the letter dated January 23, 2012 (the “January Comment Letter”) of the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the above-referenced filings.
As discussed with Al Pavot of the Staff
on February 2, 2012, the Company respectfully requests an extension of time to respond to the Commission’s comments. The
Company expects to be in a position to provide its response no later than April 3, 2012.
The Company has entered into a new engagement
with the Strategic Equity Group, an independent valuation firm hired by the Company in connection with the acquisition of Sole-Vision
Technologies, Inc. (“MegaSys”), to perform impairment testing of goodwill carried on the Company’s financial
statements and evaluate the status of the original purchase allocation. The Company is evaluating whether there will be a material
change in our goodwill valuation based on the operating results of MegaSys in the year ended December 31, 2011. In addition, the
Company is currently engaged with its annual audit and our auditors will be testing the original purchase price allocation and
any updated impairment results.
With respect to your request in comment
3 in your January 23, 2012 letter, the Company will amend the Form 10-K filed on March 30, 2011 to include the Disclosure Schedule
to the Share Exchange Agreement no later than February 8, 2012.
If the Staff is in agreement with this
request for additional time to respond, the Company will provide a comprehensive response to the January Comment Letter on or before
April 3, 2012.
Thank you for your consideration of this
request.
Sincerely yours,
/s/ Lynne Phillis
Lynne Phillis
Controller
Iveda Solutions, Inc.