SEC Comment Letter for Hartford Creative Group, Inc. (HFUS) (CIK 0001482554) (HFUS) — Mar 6, 2015
Hartford Creative Group, Inc. (HFUS) (CIK 0001482554)
Date: March 6, 2015 · CIK: 0001482554 · Accession: 0000000000-15-013750
AI Filing Summary & Sentiment
Reasoning
Letter
March 6, 2015 Via E -mail Robert Heckes Chief Executive Officer, PhotoAmigo, Inc. 2532 Foothill Rd. Santa Barbara, CA 93105
Re: PhotoAmigo, Inc. Form 10 -K for Fiscal Year Ended July 31, 2014 Filed November 12, 2014 File No. 000 -54439
Dear Mr. Heckes :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to y our facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Item 9.A Controls and Procedures
Management’s Annual Report on Internal Control Over Financi al Reporting, page 22
1. Please amend your filing to include a statement identifying the framework used to evaluate the effectiveness of your internal control over financial reporting. Refer to Item 308(a)(2) of Regulation S -K.
We urge all persons who ar e responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. 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 responding to our comment, please provide a written statement from the company acknowledging that:
Robert Heckes PhotoAmigo, Inc. March 6, 2015 Page 2
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.
You may contact Rebekah Lindsey, Staff Accountant at (202) 551 -3303 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3406 with any other questions.
Sincerely,
/s/ Patrick Gilmore
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March 6, 2015 Via E -mail Robert Heckes Chief Executive Officer, PhotoAmigo, Inc. 2532 Foothill Rd. Santa Barbara, CA 93105 Re: PhotoAmigo, Inc. Form 10 -K for Fiscal Year Ended July 31, 2014 Filed November 12, 2014 File No. 000 -54439 Dear Mr. Heckes : We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to y our facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Item 9.A Controls and Procedures Management’s Annual Report on Internal Control Over Financi al Reporting, page 22 1. Please amend your filing to include a statement identifying the framework used to evaluate the effectiveness of your internal control over financial reporting. Refer to Item 308(a)(2) of Regulation S -K. We urge all persons who ar e responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. 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 responding to our comment, please provide a written statement from the company acknowledging that: Robert Heckes PhotoAmigo, Inc. March 6, 2015 Page 2 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. You may contact Rebekah Lindsey, Staff Accountant at (202) 551 -3303 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3406 with any other questions. Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief