Amendment to Annual Report by a Small Business — Form 10-KSB Filing Table of Contents
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1: 10KSB/A Amendment to Annual Report by a Small Business HTML 23K
4: CORRESP ¶ Comment-Response or Other Letter to the SEC HTML 14K
2: EX-31.1 Certification -- SOA'02 §302 HTML 14K
3: EX-31.2 Certification -- SOA'02 §302 HTML 14K
Delayed-Release ‘CORRESP’ — Comment-Response or Other Letter to the SEC
You
disclose that this section is not applicable. Please provide the
disclosures required by Items 307 and 308(c) of Regulation
S-B.
We
have
concurrently filed Amendment No. 2 to Form 10-KSB, a copy of which is enclosed
herewith.
********
We
hereby
acknowledge that: (i) the Company is responsible for the adequacy and
accuracy of the disclosure in the filings; (ii) 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 (iii) the Company 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.
To
the
extent that you have any questions regarding the response contained in this
letter, please do not hesitate to contact me or our outside counsel, Jeffrey
E.
Jordan, Esq. of Arent Fox LLP at 202-857-6473.
Sincerely,
/s/ David
J.
Barrett
David
J. Barrett
Chief
Financial Officer
cc:
Gary
T. Shearman
Jeffrey E. Jordan,
Esq.
Dates Referenced Herein and Documents Incorporated by Reference