SEC Comment Letter for RYVYL Inc. (RTB) (CIK 0001419275) (RTB) — Apr 18, 2013
RYVYL Inc. (RTB) (CIK 0001419275)
Date: April 18, 2013 · CIK: 0001419275 · Accession: 0000000000-13-021014
AI Filing Summary & Sentiment
Reasoning
Letter
April 18, 2013 Via E -mail Frank Yuan Chief Executive Officer ASAP Expo, Inc. 345 S Figueroa St., Suite M09 Los Angeles, CA 90071
Re: ASAP Expo, Inc. Form 8-K Filed on April 18, 2013 File No. 001 -34294
Dear Mr. Yuan :
We have reviewed your filing and have the following comment. We think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review 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 comment or any other aspect of our review. F eel free to call us at the telephone numbers listed at the end of this letter.
Form 8 -K filed on April 18, 2013
Exhibit 16
1. You are reminded that Item 304 (a)(3) of Regulation S -K requires an amendment to your filing to include a letter from your former accountant within ten business days. The letter should indicate whether or not they agree with your disclosures in your Form 8 -K.
Please amend your filing and respond to these comments within five business days or tell us when you will respond. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
Frank Yuan ASAP Expo, Inc. April 1 8, 2013 Page 2
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 information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. 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.
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 com pany 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 advised that the Division of Enforcement has access to all informati on you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
You may contact Tamara Tangen, Staff Accountant , at (202) 551 -3443 if you have questions regarding comments on the financial statements and re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3730 .
Sincerely,
/s/ Stephen G. Krikorian
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April 18, 2013 Via E -mail Frank Yuan Chief Executive Officer ASAP Expo, Inc. 345 S Figueroa St., Suite M09 Los Angeles, CA 90071 Re: ASAP Expo, Inc. Form 8-K Filed on April 18, 2013 File No. 001 -34294 Dear Mr. Yuan : We have reviewed your filing and have the following comment. We think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments. Please understand that the purpose of our review 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 comment or any other aspect of our review. F eel free to call us at the telephone numbers listed at the end of this letter. Form 8 -K filed on April 18, 2013 Exhibit 16 1. You are reminded that Item 304 (a)(3) of Regulation S -K requires an amendment to your filing to include a letter from your former accountant within ten business days. The letter should indicate whether or not they agree with your disclosures in your Form 8 -K. Please amend your filing and respond to these comments within five business days or tell us when you will respond. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. Frank Yuan ASAP Expo, Inc. April 1 8, 2013 Page 2 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 information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. 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. 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 com pany 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 advised that the Division of Enforcement has access to all informati on you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing. You may contact Tamara Tangen, Staff Accountant , at (202) 551 -3443 if you have questions regarding comments on the financial statements and re lated matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3730 . Sincerely, /s/ Stephen G. Krikorian Stephen G. Krikorian Accounting Branch Chief