SEC Comment Letter for BTCS Inc. (BTCS) (CIK 0001436229) (BTCS) — Jul 5, 2011
BTCS Inc. (BTCS) (CIK 0001436229)
Date: July 5, 2011 · CIK: 0001436229 · Accession: 0000000000-11-040663
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-151252
Referenced dates: June 10, 2011
Letter
July 5, 2011 Via E-mail Andrew Brabin Chief Financial Officer TouchIT Technologies, Inc. 12 Sirdar Road Rayleigh, Essex UK, SS6 7XF Re: TouchIT Technologies, Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed March 31, 2011 File No. 333-151252
Dear Mr. Brabin: We have reviewed your letter dated J une 17, 2011 in connection with the above- referenced filings and have the following commen ts. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have addi tional comments. Unless otherwise noted, where prior comments are referred to they re fer to our letter dated June 10, 2011. Form 10-K for the Fiscal Year Ended December 31, 2010
Item 9A. Controls and Procedures, page 18
1. We acknowledge that you completed manageme nt’s report on ICFR and concluded such controls to be effective. However, as i ndicated in prior comment 2, the failure to file
management's report on ICFR rendered your annu al report materially deficient and also rendered the Company not timely or current in its 1934 Exchange Act Reporting. In light of these facts, we do not believe you could c onclude that your disc losure controls and procedures were effective as of the end of the fi scal year. Accordingly, we reissue our comment to either revise management's conclusion on the effectiveness of your disclosure controls and procedures to be that they were ineffective or tell us why you believe such revision is not considered necessary.
Andrew Brabin TouchIT Technologies, Inc. July 5, 2011 Page 2
You may contact Melissa Feid er at (202) 551-3379 if you have questions regarding comments on the financial statements and relate d matters. Please contact me at (202) 551-3499 with any other questions. Sincerely, /s/ Melissa Feider for
Kathleen Collins Accounting Branch Chief
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July 5, 2011
Via E-mail
Andrew Brabin Chief Financial Officer TouchIT Technologies, Inc. 12 Sirdar Road Rayleigh, Essex UK, SS6 7XF
Re: TouchIT Technologies, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2010
Filed March 31, 2011 File No. 333-151252
Dear Mr. Brabin:
We have reviewed your letter dated J une 17, 2011 in connection with the above-
referenced filings and have the following commen ts. In some of our comments, we may ask you
to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have addi tional comments. Unless otherwise noted, where
prior comments are referred to they re fer to our letter dated June 10, 2011.
Form 10-K for the Fiscal Year Ended December 31, 2010
Item 9A. Controls and Procedures, page 18
1. We acknowledge that you completed manageme nt’s report on ICFR and concluded such
controls to be effective. However, as i ndicated in prior comment 2, the failure to file
management's report on ICFR rendered your annu al report materially deficient and also
rendered the Company not timely or current in its 1934 Exchange Act Reporting. In light
of these facts, we do not believe you could c onclude that your disc losure controls and
procedures were effective as of the end of the fi scal year. Accordingly, we reissue our
comment to either revise management's conclusion on the effectiveness of your
disclosure controls and procedures to be that they were ineffective or tell us why you
believe such revision is not considered necessary.
Andrew Brabin TouchIT Technologies, Inc. July 5, 2011
Page 2
You may contact Melissa Feid er at (202) 551-3379 if you have questions regarding
comments on the financial statements and relate d matters. Please contact me at (202) 551-3499
with any other questions.
Sincerely, /s/ Melissa Feider for
Kathleen Collins Accounting Branch Chief