SEC – ‘UPLOAD’ from 3/23/05 re: Advanced Proteome Therapeutics Corp – ‘LETTER’

On:  Wednesday, 3/23/05, at 4:16pm ET   ·   Private-to-Public:  Filing ¶  –  Release Delayed to:  3/28/06   ·   Accession #:  0-5-13670

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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                   3±    13K 

Document Table of Contents

Mail Stop 0510                                                                  

March 22, 2005                                                      

via U.S. mail and facsimile                                                     

Mr. Ben Catalano                                                                
President                                                                       
ThrillTime Entertainment International, Inc.                                    
322-4585 Canada Way                                                             
Burnaby, British Columbia, V5G 4L6                                              

RE: Form 20-F for the fiscal year ended July 31, 2004           
File No. 0-29328                          

Dear Mr. Catalano:                                                              

        We have reviewed your response letter dated February 24,
2005 and have the following additional comments.  If you disagree               
with our comment, we will consider your explanation as to why our               
comment is inapplicable or a revision is unnecessary.  Please be                
as                                                                              
detailed as necessary in your explanation.                                      

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 filing.              
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.                                                      

FORM 20-F FOR YEAR ENDED JULY 31, 2004                                          

Item 5. Operating and Financial Review and Prospects                            

Critical Accounting Policies                                                    

1. We have reviewed your response to comment 2.  Please confirm                 
that                                                                            
your response will be incorporated in future filings or provide us              
with a supplemental response of your proposed prospective                       
disclosures.                                                                    

Liquidity and Capital Resources                                                 

2. We have reviewed your response to comment 3.  Please confirm                 
that                                                                            
your response will be incorporated in future filings or provide us              
with a supplemental response of your proposed prospective                       
disclosures.  Please also incorporate where applicable the issues               
discussed under Current Situation in your response to our comment               
letter.                                                                         

3. We have reviewed your response to comment 4.  Please confirm                 
that                                                                            
your response will be incorporated in future filings or provide us              
with a supplemental response of your proposed prospective                       
disclosures.                                                                    

Tabular Disclosure of Contractual Obligations                                   

4. We have reviewed your response to comment 5.  Please confirm                 
that                                                                            
your response will be incorporated in future filings or provide us              
with a supplemental response of your proposed prospective                       
disclosures.                                                                    

Note 2.  (i) Revenue recognition                                                

5. We have reviewed your response to comment 9.  Please revise                  
your                                                                            
revenue classifications in future filings to distinguish between                
sales of parts and other revenues and provide us with a                         
supplemental                                                                    
response of your proposed prospective disclosures.                              

FORM 6-K FOR PERIOD ENDED JANUARY 31, 2005                                      

Comments applicable to your interim filing                                      

6. Please address the comments above in your interim filings as                 
well.                                                                           

*    *    *    *                                                                

   Please respond to these comments within 10 business
days,                                                                           
or tell us when you will provide us with a response.  Please                    
provide                                                                         
us with a supplemental response letter that keys your responses to              
our comments and provides any requested supplemental information.               
Detailed letters greatly facilitate our review.  Please file your               
supplemental response on EDGAR as a correspondence file.  Please                
understand that we may have additional comments after reviewing                 
your                                                                            
responses to our comments.                                                      

If you have any questions regarding these comments, please        
direct them to Gus Rodriguez, Staff Accountant, at (202) 824-5524               
or,                                                                             
in his absence, Jeanne Baker, Assistant Chief Accountant, at (202)              
942-1835 or, to the undersigned, at (202) 942-1774.                             

                                          Sincerely,

                                            Rufus Decker
                                                       Accounting Branch Chief

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Mr. Ben Catalano                                                                
March 22, 2005                                                                  
Page 3 of 3                                                                     

UNITED STATES                                                                   
SECURITIES AND EXCHANGE COMMISSION                                              
WASHINGTON, D.C. 20549-0510                                                     

DIVISION OF                                                   
CORPORATION FINANCE                                                             

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Release Delayed to:		3/28/06		CORRESP,  UPLOAD
Filed on:		3/23/05		UPLOAD
		3/22/05		UPLOAD
		2/24/05		CORRESP,  UPLOAD
		1/31/05		6-K,  UPLOAD
		7/31/04		20-F,  6-K
				List all Filings

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

12/27/04  Advanced Proteome Theraps Corp.   20-F        7/31/04    1:766K                                   e3 Fil… Computershare/FA