SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for iQSTEL Inc (IQST) (CIK 0001527702) (IQST) — Jan 17, 2017

iQSTEL Inc (IQST) (CIK 0001527702)
Date: Jan. 17, 2017 · CIK: 0001527702 · Accession: 0000000000-17-001670

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-176376

Date
January 17, 2017
Author
/s/ W. John Cash
Form
UPLOAD
Company
iQSTEL Inc (IQST) (CIK 0001527702)

Letter

Mail Stop 4631 January 17, 2017 Via E -mail Mr. Patrick Gosselin Chief Executive Officer PureSnax International, Inc. 1000 Woodbridge Center Drive, Suite 213 Woodbridge, NJ 07095

Re: PureSnax International, Inc. Form 10 -K for the Fiscal Year Ended June 30, 2016 Filed October 14 , 2016 Form 10 -Q for the Fiscal Quarter Ended September 30, 2016 Filed November 21, 2016 File No. 333-176376

Dear Mr. Gosselin :

We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments, we may have additional comments.

Form 10 -K for the Fiscal Year Ended June 30, 2016 Item 8. Unaudited Financial Statements and Supplementary Data 1. We note that your annual report does not include an audit o pinion. In this regard, please amend your Form 10 -K to include an audit report from a PCAOB -registered independent public accounting firm. Refer to Rule 2.02 of Regulation S -X. We remind you that your amendment should include the entire “Item” that has been amended, as well as certifications that are currently dated and refer to the Form 10 -K/A. Item 9A. Controls and Procedures 2. Please amend your filing to provide the disclosures required under Item 9A of Form 10-K. We remind you that your Item 9A disclosures should include:

Mr. Patrick Gosselin PureSnax International, Inc. January 17, 2017 Page 2

 disclosure of your conclusion on the effectiveness of your disclosure controls and procedures;  management’s annual report on internal control over financial reporting, including management’s conclusion as to whether your interna l controls over financial reporting is either effective or not effective ;  clarification of which version, 1992 or 2013 , of the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission’s Internal Control — Integrated Framework you utilized when performing your assessment of internal control over financial reporting ; and  disclosure of whether there were any changes in your internal controls over financial reporting during the latest fiscal quarter. Refer to Items 307 a nd 308 of Regulation S -K. Exhibit 32.1 3. Please revise your Section 906 certification to use the correct name of your company, as it currently references B -Maven. XBRL Data Exhibits 4. Please amend your annual report to include the interactive data exhibits required by Item 601(b)(101) of Regulation S -K. Form 10 -Q for the Fiscal Quarter Ended September 30, 2016 XBRL Data Exhibits 5. Please amend your quarterly report to include the int eractive data exhibits required by Item 601(b)(101) of Regulation S -K.

We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

You may contact Dale Welcome at (202) 551 -3865 or Ernest Greene at (202) 551 -3733 with any questions.

Sincerely,
/s/ W. John Cash

Show Raw Text
Mail Stop 4631

January 17, 2017

Via E -mail
Mr. Patrick Gosselin
Chief Executive  Officer
PureSnax International, Inc.
1000 Woodbridge Center Drive, Suite 213
Woodbridge, NJ   07095

Re: PureSnax International, Inc.
 Form 10 -K for the Fiscal Year Ended June 30, 2016
 Filed October 14 , 2016
 Form 10 -Q for the Fiscal Quarter Ended September 30, 2016
 Filed November 21, 2016
 File No. 333-176376

Dear Mr. Gosselin :

We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond  to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments, we  may have additional comments.

Form 10 -K for the Fiscal Year Ended June 30, 2016
Item 8. Unaudited Financial Statements and Supplementary Data
1. We note that your annual report does not include an audit o pinion.  In this regard, please
amend your Form 10 -K to include an audit report from a PCAOB -registered independent
public accounting firm.  Refer to Rule 2.02 of Regulation S -X.  We remind you that your
amendment should include the entire “Item” that has been amended, as well as
certifications that are currently dated and refer to the Form 10 -K/A.
Item 9A. Controls and Procedures
2. Please amend your filing to provide the disclosures required under Item 9A of Form
10-K.  We remind you that your Item 9A disclosures should include:

Mr. Patrick Gosselin
PureSnax International, Inc.
January 17, 2017
Page 2

  disclosure of your conclusion on the effectiveness of your disclosure controls and
procedures;
 management’s annual report on internal control over financial reporting, including
management’s conclusion as to whether your interna l controls over financial
reporting is either effective or not effective ;
 clarification of which version, 1992 or 2013 , of the criteria set forth by the
Committee of Sponsoring Organizations of the Treadway Commission’s Internal
Control — Integrated Framework  you utilized when performing your assessment
of internal control over financial reporting ; and
 disclosure of whether there were any changes in your internal controls over
financial reporting during the latest fiscal quarter.
Refer to Items 307 a nd 308 of Regulation S -K.
Exhibit 32.1
3. Please revise your Section 906 certification to use the correct name of your company, as
it currently references B -Maven.
XBRL Data Exhibits
4. Please amend your annual report to include the interactive data exhibits required by Item
601(b)(101) of Regulation S -K.
Form 10 -Q for the Fiscal Quarter Ended September 30, 2016
XBRL Data Exhibits
5. Please amend your quarterly report to include the int eractive data exhibits required by
Item 601(b)(101) of Regulation S -K.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Dale Welcome at (202) 551 -3865 or Ernest Greene at (202) 551 -3733
with any questions.

Sincerely,

 /s/ W. John Cash

W. John Cash
Accounting Branch Chief
Office of Manufacturing and
Construction

Mr. Patrick Gosselin
PureSnax International, Inc.
January 17, 2017
Page 3