SEC Company Response from SOBR Safe, Inc. (SOBR) (CIK 0001425627) (SOBR) — Oct 3, 2014
SOBR Safe, Inc. (SOBR) (CIK 0001425627)
Date: Oct. 3, 2014 · CIK: 0001425627 · Accession: 0001477932-14-005253
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-53316
Referenced dates: June 27, 2014
Letter
United States Securities and Exchange Commission Division of Corporation Finance TransBiotec, Inc. Item 4.01 Form 8-K Filed April 15, 2014 File No. 000-53316
Dear Ms. Shenk:
We herein provide the following responses to your comment letter dated June 27, 2014, regarding the above-mentioned Current Report on Form 8-K (the “Original Filing”) for TransBiotec, Inc. (the “Company”). I have summarized your comments in bold followed by the Company’s response.
General
1.
We note that you have requested that Ronald R. Chadwick, P.C. furnish you with a letter stating whether they agreed with the statements made in this Form 8-K. Item 3-04 of Regulation S-K requires this letter to be filed with the Commission within ten days after the filing of the report. Please amend your Form 8-K to include the required letter from your former auditor.
The Company has contacted Ronald R. Chadwick, P.C. on several occasions to request that it supply the required letter. However, Ronald R. Chadwick, P.C. is refusing to furnish the required letter until it is paid all amounts it alleges are due to it from the Company. At this time the Company is not in a financial position to pay Ronald R. Chadwick, P.C. the amounts it claims are owed, and, as a result, has not been able to obtain the required letter. Notably, Ronald R. Chadwick, P.C. has not claimed that it cannot or will not supply the required letter and has not made any statements to the Company to indicate that it in any way disagrees with the Company’s disclosure in the Form 8-K. The Company will continue to attempt to obtain the letter from Ronald R. Chadwick, P.C. but at this time does not believe it will get the letter until Ronald R. Chadwick is paid in full. Once the Company obtains the letter it will file an amended Form 8-K/A and include the required letter.
LAW OFFICES OF CRAIG V. BUTLER
Lyn Shenk, Branch Chief
United States Securities and Exchange Commission
Division of Corporation Finance
October 3, 2014
Page 2
Company’s Statements
·
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 federal securities laws of the United States.
Please do not hesitate to contact me if you have any questions. Thank you for your time and attention to this matter.
Sincerely,
/s/ Craig V. Butler
Craig V. Butler, Esq.
LAW OFFICES OF CRAIG V. BUTLER
Lyn Shenk, Branch Chief
United States Securities and Exchange Commission
Division of Corporation Finance
October 3, 2014
Page 3
[TransBiotec, Inc. Letterhead]
October 3, 2014
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Attn: Lyn Shenk, Branch Chief
Re:
TransBiotec, Inc.
Item 4.01 Form 8-K
Filed April 15, 2014
File No. 000-53316
Dear Ms. Shenk:
TransBiotec, Inc. (the “Company”) hereby affirms and agrees with the following statements related to the comment response for the above-mentioned filing filed with the Commission on October 3, 2014:
Company’s Statements
·
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 federal securities laws of the United States.
Please do not hesitate to contact me if you have any questions. Thank you for your time and attention to this matter.
Sincerely,
/s/ Charles Bennington
Show Raw Text
CORRESP 1 filename1.htm LAW OFFICES OF CRAIG V. BUTLER 9900 Research Drive Irvine, California 92618 Telephone No. (949) 484-5667 • Facsimile No. (949) 209-2545 www.craigbutlerlaw.com cbutler@craigbutlerlaw.com October 3, 2014 United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549 Attn: Lyn Shenk, Branch Chief Re: TransBiotec, Inc. Item 4.01 Form 8-K Filed April 15, 2014 File No. 000-53316 Dear Ms. Shenk: We herein provide the following responses to your comment letter dated June 27, 2014, regarding the above-mentioned Current Report on Form 8-K (the “Original Filing”) for TransBiotec, Inc. (the “Company”). I have summarized your comments in bold followed by the Company’s response. General 1. We note that you have requested that Ronald R. Chadwick, P.C. furnish you with a letter stating whether they agreed with the statements made in this Form 8-K. Item 3-04 of Regulation S-K requires this letter to be filed with the Commission within ten days after the filing of the report. Please amend your Form 8-K to include the required letter from your former auditor. The Company has contacted Ronald R. Chadwick, P.C. on several occasions to request that it supply the required letter. However, Ronald R. Chadwick, P.C. is refusing to furnish the required letter until it is paid all amounts it alleges are due to it from the Company. At this time the Company is not in a financial position to pay Ronald R. Chadwick, P.C. the amounts it claims are owed, and, as a result, has not been able to obtain the required letter. Notably, Ronald R. Chadwick, P.C. has not claimed that it cannot or will not supply the required letter and has not made any statements to the Company to indicate that it in any way disagrees with the Company’s disclosure in the Form 8-K. The Company will continue to attempt to obtain the letter from Ronald R. Chadwick, P.C. but at this time does not believe it will get the letter until Ronald R. Chadwick is paid in full. Once the Company obtains the letter it will file an amended Form 8-K/A and include the required letter. LAW OFFICES OF CRAIG V. BUTLER Lyn Shenk, Branch Chief United States Securities and Exchange Commission Division of Corporation Finance October 3, 2014 Page 2 Company’s Statements · 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 federal securities laws of the United States. Please do not hesitate to contact me if you have any questions. Thank you for your time and attention to this matter. Sincerely, /s/ Craig V. Butler Craig V. Butler, Esq. LAW OFFICES OF CRAIG V. BUTLER Lyn Shenk, Branch Chief United States Securities and Exchange Commission Division of Corporation Finance October 3, 2014 Page 3 [TransBiotec, Inc. Letterhead] October 3, 2014 United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549 Attn: Lyn Shenk, Branch Chief Re: TransBiotec, Inc. Item 4.01 Form 8-K Filed April 15, 2014 File No. 000-53316 Dear Ms. Shenk: TransBiotec, Inc. (the “Company”) hereby affirms and agrees with the following statements related to the comment response for the above-mentioned filing filed with the Commission on October 3, 2014: Company’s Statements · 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 federal securities laws of the United States. Please do not hesitate to contact me if you have any questions. Thank you for your time and attention to this matter. Sincerely, /s/ Charles Bennington Charles Bennington President