SEC – ‘UPLOAD’ from 8/31/06 re: International Hi Tech Industries Inc – ‘LETTER’

On:  Thursday, 8/31/06, at 3:28pm ET   ·   Private-to-Public:  Filing ¶  –  Release Delayed to:  12/29/06   ·   Accession #:  0-6-42311

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Delayed-Release Comment or Other Letter from the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                   4±    15K 


August 31, 2006                                                     

Via U.S. Mail and Facsimile                                                     

Roger A. Rached                                                                 
Chief Executive Officer                                                         
International Hi-Tech Industries Inc.                                           
1096 West 10th Avenue                                                           
Vancouver, British Columbia, Canada, V6H 1H8                                    

RE:     International Hi-Tech Industries Inc.                                   
Form 20-F, Amendment No. 2, for the fiscal year ended           
December                                                                        
31, 2005                                                                        
File No. 1-13024                                                

Dear Mr. Rached:                                                                

We have limited our review of your Form 20-F, Amendment No. 2, for              
the fiscal year ended December 31, 2005, to disclosures relating                
to                                                                              
your contacts with countries that have been identified as state                 
sponsors of terrorism.  Our review with respect to this issue does              
not preclude further review by the Assistant Director group with                
respect to other issues.  At this juncture, we are asking you to                
provide us with supplemental information, so that we may better                 
understand your disclosure.  Please be as detailed as necessary in              
your response. After reviewing this information, we may raise                   
additional comments.                                                            

Please understand that the purpose of our review process is         
to                                                                              
assist you in your compliance with the applicable disclosure                    
requirements and to enhance the overall disclosure in your                      
filings.                                                                        
We look forward to working with you in these respects.  We welcome              
any questions you may have about our comments or on any other                   
aspect                                                                          
of our review.  Feel free to call us at the telephone numbers                   
listed                                                                          
at the end of this letter.                                                      

General -                                                                       

We note that your 20-F states that you have received patents for                
your                                                                            
technology in Cuba, Iran, North Korea, Sudan and Syria.  Each of                
these countries has been identified by the U.S. State Department                
as a                                                                            
state sponsor of terrorism, and is subject to U.S. economic                     
sanctions.  Please describe for us the extent and nature of your                
past, current, and anticipated contacts with those countries, if                
any,                                                                            
whether through subsidiaries, affiliated entities, joint ventures,              
or                                                                              
through other direct or indirect arrangements.                                  

Discuss for us the materiality to you of your contacts with Cuba,               
Iran, North Korea, Sudan and Syria, individually and in the                     
aggregate, and whether those contacts, individually or in the                   
aggregate, constitute a material investment risk for your security              
holders.  Please address materiality in quantitative terms,                     
including                                                                       
the dollar amounts of any associated assets and liabilities, and                
revenues.  Please also address materiality in terms of qualitative              
factors that a reasonable investor would deem important in making               
an                                                                              
investment decision, including the potential impact of corporate                
activities upon a company`s reputation and share value.                         

We note, for example, that Arizona and Louisiana have adopted                   
legislation that requires their state retirement systems to                     
prepare                                                                         
reports regarding state pension fund assets invested in, and/or                 
permits divestment of state pension fund assets from, companies                 
that                                                                            
do business with U.S.-designated state sponsors of terrorism.  The              
Pennsylvania legislature has adopted a resolution directing its                 
Legislative Budget and Finance Committee to report annually to the              
General Assembly regarding state funds invested in companies that               
have ties to terrorist-sponsoring countries.  Illinois, Maine, New              
Jersey and Oregon have adopted legislation requiring reporting of               
interests in, or divestment from, companies that do business with               
Sudan, and similar legislation has been proposed by several other               
states.  The Missouri Investment Trust has established an equity                
fund                                                                            
for the investment of certain state-held monies that screens out                
stocks of companies that do business with U.S.-designated state                 
sponsors of terrorism.  Florida requires that issuers disclose in               
their prospectuses any business contacts with Cuba or persons                   
located                                                                         
in Cuba.  Finally, Harvard University, Yale University, Stanford                
University, and other educational institutions have adopted                     
policies                                                                        
prohibiting investment in, and/or requiring divestment from,                    
companies that do business with Sudan.  Your materiality analysis               
should address the potential impact of the investor sentiment                   
evidenced by such actions directed toward companies that operate                
in                                                                              
Cuba, Iran, North Korea, Sudan and Syria.                                       

Closing Comments                                                                

Please respond to this comment within 10 business days or           
tell                                                                            
us when you will provide us with a response.  Please file your                  
response letter on EDGAR.                                                       

We urge all persons who are responsible for the accuracy and        
adequacy of the disclosure in the filings to be certain that the                
filings include all information required under the Exchange Act of              
1934 and that they have provided all information investors require              
for an informed investment decision.  Since the company and its                 
management are in possession of all facts relating to the                       
company`s                                                                       
disclosure, they are responsible for the accuracy and adequacy of               
the                                                                             
disclosures they have made.                                                     

In connection with responding to our comment, please                
provide,                                                                        
in writing, a statement from the company acknowledging that:                    

the company is responsible for the adequacy and accuracy of the                 
disclosure in the filings;                                                      

staff comments or changes to disclosure in response to staff                    
comments                                                                        
do not foreclose the Commission from taking any action with                     
respect                                                                         
to the filings; and                                                             

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.                                   

In addition, please be advised that the Division of Enforcement                 
has                                                                             
access to all information you provide to the staff of the Division              
of                                                                              
Corporation Finance in our review of your filings or in response                
to                                                                              
our comments on your filings.                                                   

Please understand that we may have additional comments after        
we                                                                              
review your response to our comment.  Please contact Jack                       
Guggenheim                                                                      
at (202) 551-3523 if you have any questions about the comment or                
our                                                                             
review.  You may also contact me at (202) 551-3470.                             

                                                          Sincerely,

                                                          Cecilia D. Blye, Chief
                                                       Office of Global Security
Risk                                                                            

Pamela Long                                                                     
Nilima Shah                                                                     
Division of Corporation Finance                                                 

Roger A. Rached                                                                 
International Hi-Tech Industries Inc.                                           
August 31, 2006                                                                 
Page 1                                                                          

UNITED STATES                                                                   
SECURITIES AND EXCHANGE COMMISSION                                              
WASHINGTON, D.C. 20549-5546                                                     

DIVISION OF                                                   
CORPORATION FINANCE                                                             

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Release Delayed to:		12/29/06		CORRESP,  UPLOAD
Filed on:		8/31/06		6-K,  UPLOAD
		12/31/05		20-F,  20-F/A
				List all Filings