SEC Comment Letter for SUI Group Holdings Ltd. (SUIG) (CIK 0001425355) (SUIG) — Feb 25, 2008
SUI Group Holdings Ltd. (SUIG) (CIK 0001425355)
Date: Feb. 25, 2008 · CIK: 0001425355 · Accession: 0000000000-08-009790
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-53045
Letter
Mail Stop 3561 February 25, 2008 Douglas M. Polinsky Poker Magic, Inc. 130 West Lake Street, Suite 300 Wayzata, MN 55391
Re: Poker Magic, Inc. Registration Statement on Form 10-SB Filed January 29, 2008 File No. 000-53045
Dear Mr. Polinsky:
We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we w ill consider your explanation as to why our comment is inapplicable or a revision is unneces sary. Please be as detailed as necessary in your explanation. In some of our comme nts, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view 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 comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
General 1. Please file your next amendment on the a ppropriate form available to you without an “SB” designation. Refer to Section IV of the Smaller Reporting Company Regulatory Relief and Simplification Rel ease (Release No. 33-8876) and A Small Entity Compliance Guide, both which are available on our website at http://www.sec.gov/rules/final/fina larchive/finalarchive2007.shtml .
Douglas M. Polinsky Poker Magic February 25, 2008 Page 2 Intellectual Property, page 7 2. Please describe the intellect ual property right you own. Specifically, discuss the nature and status of any pa tents, trademarks, copyrights or other rights you own. In addition, discuss how and to whom you intend to license your intellectual property.
* * * * *
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of th e amendment to expedite our review. Please furnish a cover letter with your amendment th at keys your responses to our comments and provides any requested information. Deta iled cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsi ble for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating 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 company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
Douglas M. Polinsky Poker Magic February 25, 2008 Page 3 You may contact John Stickel at (202) 551-3324 or me at (202) 551-3750 if you have any questions.
R e g a r d s ,
A m a n d a M c M a n u s B r a n c h C h i e f – L e g a l
Show Raw Text
Mail Stop 3561
February 25, 2008
Douglas M. Polinsky
Poker Magic, Inc.
130 West Lake Street, Suite 300
Wayzata, MN 55391
Re: Poker Magic, Inc.
Registration Statement on Form 10-SB
Filed January 29, 2008
File No. 000-53045
Dear Mr. Polinsky:
We have limited our review of your filing to those issues we have addressed in
our comments. Where indicated, we think you should revise your document in response
to these comments. If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary. Please be as detailed as necessary
in your explanation. In some of our comme nts, we may ask you to provide us with
information so we may better understand your disclosure. After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view 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 comments or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
General
1. Please file your next amendment on the a ppropriate form available to you without
an “SB” designation. Refer to Section IV of the Smaller Reporting Company Regulatory Relief and Simplification Rel ease (Release No. 33-8876) and A Small
Entity Compliance Guide, both which are available on our website at
http://www.sec.gov/rules/final/fina larchive/finalarchive2007.shtml .
Douglas M. Polinsky
Poker Magic
February 25, 2008 Page 2
Intellectual Property, page 7
2. Please describe the intellect ual property right you own. Specifically, discuss the
nature and status of any pa tents, trademarks, copyrights or other rights you own.
In addition, discuss how and to whom you intend to license your intellectual
property.
* * * * *
As appropriate, please amend your filing and respond to these comments
within 10 business days or tell us when you will provide us with a response. You may
wish to provide us with marked copies of th e amendment to expedite our review. Please
furnish a cover letter with your amendment th at keys your responses to our comments
and provides any requested information. Deta iled cover letters greatly facilitate our
review. Please understand that we may have additional comments after reviewing your
amendment and responses to our comments.
We urge all persons who are responsi ble for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating 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 company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
Douglas M. Polinsky
Poker Magic
February 25, 2008 Page 3
You may contact John Stickel at (202) 551-3324 or me at (202) 551-3750 if you
have any questions.
R e g a r d s ,
A m a n d a M c M a n u s
B r a n c h C h i e f – L e g a l