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SEC Comment Letter for Artificial Intelligence Technology Solutions Inc. (AITX) (CIK 0001498148) (AITX) — Aug 31, 2010

Artificial Intelligence Technology Solutions Inc. (AITX) (CIK 0001498148)
Date: Aug. 31, 2010 · CIK: 0001498148 · Accession: 0000000000-10-050614

AI Filing Summary & Sentiment

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File numbers found in text: 333-168530

Date
August 31, 2010
Author
Not clearly detected
Form
UPLOAD
Company
Artificial Intelligence Technology Solutions Inc. (AITX) (CIK 0001498148)

Letter

August 31, 2010 John B. Crawford Chief Executive Officer On the Move Systems Corp. 7674 37 th Street Circle East Sarasota, FL 34243 Re: On the Move Systems Corp. Registration Statement on Form S-1 Filed August 4, 2010 File No. 333-168530

Dear Mr. Crawford:

We have reviewed your registration statem ent and have the following comments. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your re gistration statement and the information you provide in response to these comments, we may have additional comments. General

1. Please revise throughout so that the re gistration statement gives an accurate representation of your business at the time of effectiveness. Throughout the filing, you discuss the company’s intentions or aspira tions, but such disclosure does not provide investors with the company’s actual status . For example, your discussions about your intent to establish relationshi ps with dealerships, government agencies, or consumers and your plans to develop a website, attend trade shows, market your pr oducts, and establish facilities in multiple states should be preceded with a discussion of the status of the company in accomplishing these goals.

Calculation of Registration Fee, page 2

2. The registration fee cannot be calculated in accordance with Rule 457(c) as there is no market for the common shares. Please revise the registration statement to recalculate the registration fee in accordance with the appropriate rule.

John B. Crawford On the Move Systems Corp. August 31, 2010 Page 2

3. Please advise as to why you have included footnote (3), as you appear to be offering a fixed number of securities for a fixed price. Alternatively, advise. Prospectus Cover Page

4. Please revise to clarify that all funds i nvested in the company will be immediately available for use by the company, and that you have made no arrangements to place the proceeds of the offering in an escrow account. Similarly revise your “Our Offering” section on page 5.

5. Please also revise to clarify th at there is no guarantee that all shares will be sold or that the total amount of offering proceeds will be raised. Similarly revise your “Our Offering” section on page 5.

6. We note your statement that the offering w ill end no later than six months from the offering date, which appears to conflict with your disclosure that the offering may only be extended for an additional 90 days after the initial 90 day offe ring period. Please reconcile here and elsewhere th roughout your filing or advise.

Dealer Prospectus Delivery Obligations, page 4

7. Please move the dealer prospectus delivery oblig ations to the outside back cover. Refer to Item 502(b) of Regulation S-K.

Market for the common shares, page 6

8. Please state here, as you do elsewhere in your filing, that you plan to apply for your stock to be quoted on the OTCBB. As you do not have plans to apply to be listed on an exchange, please delete your reference to a “public listing” or bei ng “granted listing.” Also revise throughout your filing.

Business Summary, page 6

9. Please disclose in one of the first paragra phs of this section the following: (1) your auditors have issued a going concern opinion; (2) your revenues and net losses since inception and your current assets; (3) that you will need to raise $425,000, in addition to the proceeds of this offering, in order to im plement your business plan; (4) that you have taken no concrete steps to implement your bus iness plan, and (5) that you are a “shell company” as defined by Rule 405 of the Securities Act.

10. Please briefly discuss the “mobile electronic services” that you plan to provide.

John B. Crawford On the Move Systems Corp. August 31, 2010 Page 3

11. Please delete reference here and throughout your filing to your warehouse and your suppliers, as it does not app ear that you have either a warehouse or suppliers. Alternatively, advise. Risk Factors, page 3

General

12. Please add a risk factor to discuss any impact the current state of the economy, including the difficulty in obtaining de bt financing, may have on your ability start your business and raise the additional $425,000 you need to implement your business plan.

13. We note in several risk factors that you di scuss needing additional capital, incurring operating expenses, and complying with SEC re porting requirements over the next twelve months. In each of these risk factors pleas e quantify the amount of additional funds that you will need, the operating expenses that you anticipate incurring, and the amount that you estimate it will cost you to comply with the reporting requirements.

14. Please add a risk factor that the executive officer is currently not receiving any compensation and disclose what compensation he ultimately expects to receive. Specifically disclose that as the sole director and officer of the company, Mr. Crawford has the power to set his own compensation.

15. Please add a risk factor to di scuss the substantial dilution th at investors that may undergo as a result of your plans to obtain $425,000 in additional financing.

Because our Current Sole Chief Executive Officer, page 8

16. Please delete the term “extensive” here a nd throughout your filing when you refer to Mr. Crawford’s business experience or advise.

Key Management Personnel May Leave the Company, page 9

17. Please describe the commercially reasonable ef forts made to minimize the risks attendant with the departure of key personnel or revise to remove this statement.

Since Our Sole Officer and Director, page 11

18. Please revise to disclose Mr. Crawford’s ownership if you sell 25% , 50% and 75% of the offered shares.

John B. Crawford On the Move Systems Corp. August 31, 2010 Page 4

If We Cannot Secure Additional Capital, page 13

19. We note that here you state you will need total funding of approximately $425,000 to fully execute your plan, which conflicts with disclosure elsewhere in your filing that states you will need $425,000 in addition to the proceeds of this offering. Please reconcile or advise. Because There Is No Public Trading Market, page 13

20. Please delete your reference to the “s elling security holders” or advise. Use of Proceeds, page 16

21. Please revise your table to include a line item for the costs you will incur to comply with your public company reporting requirements. Please also break-out the “Implementation of Business Plan” line item to allocate th e exact amount of proceeds you will use for each element of your business plan and provide th e basis for the amount of each allocation. Similarly break-out your “Administration Expens es” line item. Please also reconcile the expense items you plan to finance with your proceeds from this offering with the anticipated expenses identified in the table on page 26 of the Plan of Operations section.

22. Please revise here and in your “Plan of Operations” and “MD&A” sections to set forth, in detail, how your business plans will change if you raise 25%, 50% , 75%, or 100% of the offering proceeds. Plan of Distribution, page 18

23. Please disclose in detail the means that your officer and director intends to use to offer the shares to the public. Discuss whether he will use written offeri ng materials or will only conduct offerings verbally. Please keep in mind that as a shell company, you cannot avail yourself of the rules permitting use of free writing prospectuses. Business Description, page 21

24. To the extent you discuss future business plans, please discuss the potential timeline for implementing each of your plans, the costs of each step of your plans, and the source of the funds. Please disclose that you will need $425,000 to implement your business plan and disclose that there is no guarantee you w ill be able to raise those additional funds. Similarly revise your “Pla n of Operations” section.

25. Please revise to provide a more detailed desc ription of your business plan. For example, disclose how you intend to generate re venue and when you anticipate generating revenues, the products and serv ices you intend to offer and th e pricing structure of these

John B. Crawford On the Move Systems Corp. August 31, 2010 Page 5

products and services, how you intend to market your product and establish relationships with dealers and other customers, and the nature of your supply relationships.

26. Please remove all references here and thr oughout to future plans to expand throughout Florida, Georgia and the Carolinas given that you are at such an early stage of develop and such expansion remains highly speculative. Alternative, pleas e provide detailed and quantifiable support for your expansion plans.

Sales and Marketing Strategy, page 22

27. We note that your first location is intended to be in Sarasota, Florida. We also note that you intend to work on-site at ve hicle dealerships. Please advi se as to whether your “first location” will be located at a ve hicle dealership and briefly de scribe the characteristics of your current location.

28. Please remove your reference independent sales representatives, as you do not appear to have any, or advise.

29. Please provide the basis for your statement that 80% of your inventory will be next day shipments and 20% will be at your warehouse, as you do not currently have a relationship with any customers or suppliers, and you do not have a warehouse. Alternatively, delete.

Market, page 23

30. Please update this section with more recent da ta or delete. To the extent known, please also provide industry and mark et data that is more speci fic to your mobile electronic services and installation business. To the extent you do not have a more specific understanding of the industry in which you will compete, please include a risk factor to discuss your limited knowledge and experi ence in regards to the industry. Employees and Employment Agreements, page 23

31. We note that Mr. Crawford has another busin ess, Crawford Mobile Install Co. Please advise as to how Mr. Crawford will be able to spend 10-25 hours per week, or more time as may be required, if he also has another bus iness. Please also discuss the relationship between you and Crawford Mobile Install Co. and whether you will be competitors. Discuss your plans for handling any conflicts between your business and Mr. Crawfords’ other business interests.

32. Please disclose the role that the independent consultants will pl ay in developing and executing your business plan. Please also di sclose the estimated cost of hiring these consultants.

John B. Crawford On the Move Systems Corp. August 31, 2010 Page 6

Management’s Discussion and Analys is of Financial Condition, page 25

Overview, page 26

33. We note your statement that the proceeds from this offering will satisfy your cash requirements for up to 6 months. Please di sclose your cash requirements for these six months and discuss how long your cash requi rements will be met if 25%, 50%, 75%, or 100% of the shares are sold. Plan of Operations, page 26

34. Please add a narrative discussion to your table to discuss, in detail, each of your anticipated expenses, including how you arrive d at your estimated budget for each line item. Please also include a discussion of how you will fund each of the budget items with either 25%, 50%, 75% or 100% of the proceeds of your offering.

35. Please add a line item to disclose the cost s of complying with your public company reporting requirements.

36. Please advise as to whether you have taken any steps to raise the additional $425,000 in funds that you will need. If you have not taken any steps, please state this.

37. We note that you intend to pursue capital thr ough other sources, in cluding your officer and director. Please advise as to whether he has entered into any agreement, either verbal or written, to give additional funds to the company. Liquidity and Capital Resources, page 28

38. Please advise as to why you believe that you ma y be able to issue not es payable or debt instruments, as you have not included any evidence that you will be able to do so. Alternatively, delete. Business Experience, page 31

39. We note your disclosure that Mr. Crawford was Sales and Installation Management of Circuit City Stores. Please revise to sp ecify whether this wa s his title or job responsibility. Please also clarify whether he was responsible for the overall management of several locations or managed a particular aspect of these locations. Please specify the number of locations for which he was responsible.

Executive Compensation, page 33

40. Please disclose what you mean by “sufficient cash flow” and clarif y, if true, that Mr. Crawford will not be paid out of the offering proceeds.

John B. Crawford On the Move Systems Corp. August 31, 2010 Page 7

Director Independence, page 36

41. Please delete the statement that your securi ties “are quoted” on the OTCBB, as they are not. Opinion of Counsel, Exhibit 5.1

42. Refer to the last sentence in the fourth paragr aph. Please either dele te this sentence or update your opinion to the da te of effectiveness. Subscription Agreement, Exhibit 99.1

43. Please include a brief description of the mate rial terms of the subscription agreement in your prospectus. Specifically include that the subscriber ha s a two day cancellation right.

44. Refer to the “Payment” section. Please advi se as to what you mean by the “Closing” and the “written notice to subscrib ers.” Alternatively, delete.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and all applicable Securities 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. Notwithstanding our comments, in the event you request acceleration of the effective date of the pending registration statement please pr ovide a written statement from the company acknowledging that: • should the Commission or the staff, acting purs uant to delegated authority, declare the filing effective, it does not foreclose the Co mmission from taking any action with respect to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert staff comments a nd the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding re quests for acceleration. We will consider a written request for acceleration of the effective date of the regi stration statement as confirmation of the fact that those reques ting acceleration are aware of thei r respective responsibilities under

John B. Crawford On the Move Systems Corp. August 31, 2010 Page 8

the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration stat ement. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. You may contact Jean Yu at (202) 551-3305 or Joe Foti at (202) 551-3816

Show Raw Text
August 31, 2010

John B. Crawford Chief Executive Officer On the Move Systems Corp. 7674 37
th Street Circle East
Sarasota, FL 34243
Re: On the Move Systems Corp.
Registration Statement on Form S-1 Filed August 4, 2010
  File No. 333-168530

Dear Mr. Crawford:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 General

1. Please revise throughout so that the re gistration statement gives an accurate
representation of your business at the time of  effectiveness.  Throughout the filing, you
discuss the company’s intentions or aspira tions, but such disclosure does not provide
investors with the company’s actual status .  For example, your discussions about your
intent to establish relationshi ps with dealerships, government  agencies, or consumers and
your plans to develop a website, attend trade shows, market your pr oducts, and establish
facilities in multiple states should be preceded with a discussion of the status of the
company in accomplishing these goals.

Calculation of Registration Fee, page 2

2. The registration fee cannot be calculated in accordance with Rule 457(c) as there is no
market for the common shares.  Please revise the registration statement to recalculate the
registration fee in accordance with the appropriate rule.

John B. Crawford On the Move Systems Corp.
August 31, 2010 Page 2

3. Please advise as to why you have included footnote (3), as you appear to be offering a fixed number of securities for a fixed price.  Alternatively, advise.
 Prospectus Cover Page

4. Please revise to clarify that all funds i nvested in the company will be immediately
available for use by the company, and that you have made no arrangements to place the
proceeds of the offering in an escrow account.  Similarly revise your “Our Offering” section on page 5.

5. Please also revise to clarify th at there is no guarantee that all shares will be sold or that
the total amount of offering proceeds will be raised.  Similarly revise your “Our Offering” section on page 5.

6. We note your statement that the offering w ill end no later than six months from the
offering date, which appears to conflict with  your disclosure that the offering may only
be extended for an additional 90 days after the initial 90 day offe ring period.  Please
reconcile here and elsewhere th roughout your filing or advise.

Dealer Prospectus Delivery Obligations, page 4

7. Please move the dealer prospectus delivery oblig ations to the outside back cover.  Refer
to Item 502(b) of Regulation S-K.

Market for the common shares, page 6

8. Please state here, as you do elsewhere in your filing, that you plan to apply for your stock
to be quoted on the OTCBB.  As you do not have plans to apply to be listed on an
exchange, please delete your reference to a “public listing” or bei ng “granted listing.”
Also revise throughout your filing.

Business Summary, page 6

9. Please disclose in one of the first paragra phs of this section the following:  (1) your
auditors have issued a going concern opinion; (2) your revenues and net losses since
inception and your current assets; (3) that you will need to raise $425,000, in addition to
the proceeds of this offering, in order to im plement your business plan; (4) that you have
taken no concrete steps to implement your bus iness plan, and (5) that you are a “shell
company” as defined by Rule 405 of the Securities Act.

10. Please briefly discuss the “mobile electronic  services” that you plan to provide.

John B. Crawford On the Move Systems Corp.
August 31, 2010 Page 3

11. Please delete reference here and throughout  your filing to your warehouse and your
suppliers, as it does not app ear that you have either a warehouse or suppliers.
Alternatively, advise.
 Risk Factors, page 3

 General

12. Please add a risk factor to discuss any impact the current state of the economy, including the difficulty in obtaining de bt financing, may have on your  ability start your business
and raise the additional $425,000 you need to implement your business plan.

13. We note in several risk factors that you di scuss needing additional capital, incurring
operating expenses, and complying with SEC re porting requirements over the next twelve
months.  In each of these risk factors pleas e quantify the amount of additional funds that
you will need, the operating expenses that you anticipate incurring, and the amount that
you estimate it will cost you to comply with the reporting requirements.

14. Please add a risk factor that the executive officer is currently not receiving any compensation and disclose what compensation he ultimately expects to receive.
Specifically disclose that as the sole director and officer of the company, Mr. Crawford
has the power to set his own compensation.

15. Please add a risk factor to di scuss the substantial dilution th at investors that may undergo
as a result of your plans to obtain $425,000 in additional financing.

Because our Current Sole Chief Executive Officer, page 8

16. Please delete the term “extensive” here a nd throughout your filing when you refer to Mr.
Crawford’s business experience or advise.

Key Management Personnel May Leave the Company, page 9

17. Please describe the commercially reasonable ef forts made to minimize the risks attendant
with the departure of key personnel or revise to remove this statement.

Since Our Sole Officer and Director, page 11

18. Please revise to disclose Mr. Crawford’s ownership if you sell 25% , 50% and 75% of the
offered shares.

John B. Crawford On the Move Systems Corp.
August 31, 2010 Page 4

If We Cannot Secure Additional Capital, page 13

19. We note that here you state you will need total funding of approximately $425,000 to fully execute your plan, which conflicts with  disclosure elsewhere in your filing that
states you will need $425,000 in addition to the proceeds of this offering.  Please reconcile or advise.
 Because There Is No Public Trading Market, page 13

20. Please delete your reference to the “s elling security holders” or advise.
 Use of Proceeds, page 16

21. Please revise your table to include a line item for the costs you will incur to comply with
your public company reporting requirements.  Please also break-out the “Implementation
of Business Plan” line item to allocate th e exact amount of proceeds you will use for each
element of your business plan and provide th e basis for the amount of each allocation.
Similarly break-out your “Administration Expens es” line item.  Please also reconcile the
expense items you plan to finance with your  proceeds from this offering with the
anticipated expenses identified in the table on page 26 of the Plan of  Operations section.

22. Please revise here and in your “Plan of Operations” and “MD&A”  sections to set forth, in
detail, how your business plans will change if you raise 25%, 50% , 75%, or 100% of the
offering proceeds.
 Plan of Distribution, page 18

23. Please disclose in detail the means that your officer and director intends to use to offer
the shares to the public.  Discuss whether he will use written offeri ng materials or will
only conduct offerings verbally.  Please keep  in mind that as a shell company, you cannot
avail yourself of the rules permitting use of free writing prospectuses.
 Business Description, page 21

24. To the extent you discuss future business plans, please discuss the potential timeline for implementing each of your plans, the costs of each step of your plans, and the source of
the funds.  Please disclose that you will need $425,000 to implement your business plan and disclose that there is no guarantee you w ill be able to raise those additional funds.
Similarly revise your “Pla n of Operations” section.

25. Please revise to provide a more detailed desc ription of your business plan.  For example,
disclose how you intend to generate re venue and when you anticipate generating
revenues, the products and serv ices you intend to offer and th e pricing structure of these

John B. Crawford On the Move Systems Corp.
August 31, 2010 Page 5

products and services, how you intend to market your product and establish relationships with dealers and other customers, and the nature of your supply relationships.

26. Please remove all references here and thr oughout to future plans to expand throughout
Florida, Georgia and the Carolinas given that you are at such an early stage of develop and such expansion remains highly speculative.   Alternative, pleas e provide detailed and
quantifiable support for your expansion plans.

Sales and Marketing Strategy, page 22

27. We note that your first location is  intended to be in Sarasota, Florida.  We also note that
you intend to work on-site at ve hicle dealerships.  Please advi se as to whether your “first
location” will be located at a ve hicle dealership and briefly de scribe the characteristics of
your current location.

28. Please remove your reference independent sales representatives, as you do not appear to
have any, or advise.

29. Please provide the basis for your statement that  80% of your inventory will be next day
shipments and 20% will be at your warehouse, as you do not currently have a relationship
with any customers or suppliers, and you do not have a warehouse.  Alternatively, delete.

Market, page 23

30. Please update this section with more recent da ta or delete.  To the extent known, please
also provide industry and mark et data that is more speci fic to your mobile electronic
services and installation business.  To the extent you do not have a more specific
understanding of the industry in which you will compete, please include a risk factor to
discuss your limited knowledge and experi ence in regards to the industry.
 Employees and Employment Agreements, page 23

31. We note that Mr. Crawford has another busin ess, Crawford Mobile  Install Co.  Please
advise as to how Mr. Crawford will be able  to spend 10-25 hours per week, or more time
as may be required, if he also has another bus iness.   Please also discuss the relationship
between you and Crawford Mobile Install Co. and whether you will be competitors.  Discuss your plans for handling any conflicts  between your business and Mr. Crawfords’
other business interests.

32. Please disclose the role that the independent  consultants will pl ay in developing and
executing your business plan.  Please also di sclose the estimated cost of hiring these
consultants.

John B. Crawford On the Move Systems Corp.
August 31, 2010 Page 6

Management’s Discussion and Analys is of Financial Condition, page 25

 Overview, page 26

33. We note your statement that the proceeds from this offering will satisfy your cash
requirements for up to 6 months.  Please di sclose your cash requirements for these six
months and discuss how long your cash requi rements will be met if 25%, 50%, 75%, or
100% of the shares are sold.
 Plan of Operations, page 26

34. Please add a narrative discussion to your table to discuss,  in detail, each of your
anticipated expenses, including how you arrive d at your estimated budget for each line
item.  Please also include a discussion of how you will fund each of  the budget items with
either 25%, 50%, 75% or 100% of the proceeds of your offering.

35. Please add a line item to disclose the cost s of complying with your public company
reporting requirements.

36. Please advise as to whether you have taken any steps to raise the additional $425,000 in
funds that you will need.  If you have not taken any steps, please state this.

37. We note that you intend to pursue capital thr ough other sources, in cluding your officer
and director.  Please advise as to whether he has entered into any agreement, either verbal
or written, to give additional funds to the company.
 Liquidity and Capital Resources, page 28

38. Please advise as to why you believe that you ma y be able to issue not es payable or debt
instruments, as you have not included any evidence that you will be able to do so.
Alternatively, delete.
 Business Experience, page 31

39. We note your disclosure that Mr. Crawford was Sales and Installation Management of
Circuit City Stores.  Please revise to sp ecify whether this wa s his title or job
responsibility.  Please also clarify whether he was responsible for the overall
management of several locations or managed a particular aspect of these locations.
Please specify the number of locations for which he was responsible.

Executive Compensation, page 33

40. Please disclose what you mean by “sufficient cash flow” and clarif y, if true, that Mr.
Crawford will not be paid out of the offering proceeds.

John B. Crawford On the Move Systems Corp.
August 31, 2010 Page 7

 Director Independence, page 36

41. Please delete the statement that your securi ties “are quoted” on the OTCBB, as they are
not.
 Opinion of Counsel, Exhibit 5.1

42. Refer to the last sentence in the fourth paragr aph.  Please either dele te this sentence or
update your opinion to the da te of effectiveness.
 Subscription Agreement, Exhibit 99.1

43. Please include a brief description of the mate rial terms of the subscription agreement in
your prospectus.  Specifically include that the subscriber ha s a two day cancellation right.

44. Refer to the “Payment” section.  Please advi se as to what you mean by the “Closing” and
the “written notice to subscrib ers.”  Alternatively, delete.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities 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.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under

John B. Crawford On the Move Systems Corp. August 31, 2010 Page 8

the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the registration statement.
 You may contact Jean Yu at  (202) 551-3305 or Joe Foti at (202) 551-3816