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SEC Comment Letter for SPLASH BEVERAGE GROUP, INC. (EDVA) (CIK 0001553788) (EDVA) — Apr 1, 2014

SPLASH BEVERAGE GROUP, INC. (EDVA) (CIK 0001553788)
Date: April 1, 2014 · CIK: 0001553788 · Accession: 0000000000-14-016166

AI Filing Summary & Sentiment

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Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 000-55114

Date
March 28, 2014
Author
/s/ Steve Lo
Form
UPLOAD
Company
SPLASH BEVERAGE GROUP, INC. (EDVA) (CIK 0001553788)

Letter

April 1 , 2014 Via E-mail Michael J. West, President Canfield Medical Supply, Inc. 4120 Boardman -Canfield Road Canfield, Ohio 44406

Re: Canfield Medical Supply, Inc. Form 8 -K Filed March 28 , 2014 File No. 000-55114

Dear Mr. West :

We have reviewed your filing an d 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 this letter within five business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstanc es or do not believe an amendment is appropriate, please 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 additional comments.

Form 8 -K Filed on March 28, 2014

1. We note that while your former accountant, Ronald R. Chadwick, P.C. resigned on September 24, 2013, you did not file your Form 8 -K report until March 28, 2014. For future filings, please note Form 8 -K General Instruction B.1.that current reports on Form 8-K should be filed within four business days after the occurrence of the event.

2. Rule 10 -01(d) of Regulation S -X requires interim financial statements filed under cover of Form 10 -Q to be reviewed by an independent public accountant using applica ble professional standards and procedures. Please confirm that the interim financial statements included in your Form 10 -Q filed on November 13, 2013 were reviewed in compliance with Rule 10 -01(d) and identify the independent registered public accounting firm that performed the review.

Michael J. West Canfield Medical Supply, Inc. March 28 , 2014 Page 2

3. Please revise or tell us why you refer to Myskin, Inc. in providing signature from your President.

We urge all persons who are 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 comments, please provide a written statement from the company acknowledging that:

 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 proce eding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact me at 202 -551-3394 if you have questions regar ding these comments and related matters.

Sincerely,
/s/ Steve Lo

Show Raw Text
April 1 , 2014

Via E-mail
Michael J. West, President
Canfield Medical Supply, Inc.
4120 Boardman -Canfield Road
Canfield, Ohio 44406

Re: Canfield Medical Supply, Inc.
 Form 8 -K
Filed March 28 , 2014
 File No. 000-55114

Dear Mr. West :

We have reviewed your filing an d 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 this letter within five business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstanc es or do not
believe an amendment is appropriate, please 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  additional comments.

Form 8 -K Filed on March 28, 2014

1. We note that while your former accountant, Ronald R. Chadwick, P.C. resigned on
September 24, 2013, you did not file your Form 8 -K report until March 28, 2014. For
future filings, please note Form 8 -K General Instruction B.1.that current reports on Form
8-K should be filed within four business days after the occurrence of the event.

2. Rule 10 -01(d) of Regulation S -X requires interim financial statements filed under cover
of Form 10 -Q to be reviewed by an independent public accountant using applica ble
professional standards and procedures.  Please confirm that the interim financial
statements included in your Form 10 -Q filed on November 13, 2013 were reviewed in
compliance with Rule 10 -01(d) and identify the independent registered public accounting
firm that performed the review.

Michael J. West
Canfield Medical Supply, Inc.
March 28 , 2014
Page 2

 3. Please revise or tell us why you refer to Myskin, Inc. in providing signature from your
President.

We urge all persons who are 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 comments, please provide  a written statement from the company
acknowledging that:

 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 proce eding initiated
by the Commission or any person under the federal securities laws of the United
States.

Please  contact me at 202 -551-3394  if you have questions regar ding these comments and related
matters.

Sincerely,

 /s/ Steve Lo

Steve Lo
Staff Acc ountant