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August 13, 2009 Securities and Exchange Commission Attn: Bret Johnson Dear Mr. Johnson: This is in response to your letter of July 23, 2009 concerning
the Annual Report on Form 10-K for the year ended December 31, 2008 of Lexon
Technologies, Inc. For ease of reference, the numbers of the following paragraphs
correspond to the numbers of the paragraphs of the staffs letter. Form 10-K for year ending December 31, 2008 Item 9. Changes in and Disagreements with Accountants on
Accounting and Financial Disclosure. Page 5 Question 1. How many hours were expended in total and by what level
of personnel (i.e, staff, supervisory and partner) within the accounting
firm, When discussions were held with your audit committee, Whether cash and debt confirmations were sent, and We had contacted Choi, Kim & Park LLP (CKP) two weeks
prior to the formal engagement with CKP. On April 10, 2009, we and CKP orally
agreed to engage in audit for the financial statements ended December 31, 2008.
CKP has performed client acceptance procedure since the oral agreement and both
parties signed the engagement letter on April 22, 2009. Audit planning and other
preliminary procedures had been performed following the oral agreement and
actual audit field work began on April 23, 2009 for other audit procedures. The partner, manager, in-charge senior, and one staff were
involved in the engagement. Approximately 200 aggregate hours were spent in
performing planning, field work, and completion of the engagement. Discussion
with board of director of Lexon Technologies, Inc (the Company) were held on
April 22, 2009 and May 4, 2009. Cash and debt confirmation letters were sent
prior to fieldwork and received during and subsequent to field work. Alternative
procedures were performed for unreturned confirmation. During CKPs work, it was
noted that the operations of Lexon Semiconductor Corporation, the majority owned
subsidiary, had ceased and that its activities should be presented as
discontinued operations. The Company provided to CKP the business suspension
certification issued by Korea National Tax Service. 1 Item 9A. Controls and Procedures, page 5 Managements Report on Internal Control Over Financial
Reporting, page 6 We will incorporate your comments in our future filings. Item 14. Principal Accountant Fees and Services, page
10 We paid Kim and Lee aggregate fees of $30,000 for the year
ended December 31, 2008 for professional services rendered for the review of
financial statements included in our quarterly reports 10-QSB and the audit of
financial statements included in 10-KSB for the year ended December 31, 2007. We
paid to CKP $20,000 for the audit of our annual financial statements included in
10-K for the year ended December 31, 2008. Audit fees for Kim and Lee was for
audit and three quarterly review services, but audit fees for CKP was for only
audit service. If there are any confusion regarding audit fees we will revise
the wording in our future filing. Exhibit 31 We will incorporate your comments in our future filings. FORM 10-Q FOR THE PERIOD ENDED MARCH 31, 2009 Item 4. Controls and Procedures, page 5 Please confirm to us, if true, and revise future filings
to clarify that your assessment of disclosure controls and procedures is
as of the end of the period covered by the report rather than within 90
days as required by Item 307 of Regulation
S-K.
450 Fifth Street,
N.W.
Washington, DC 20549
Re:
Lexon Technologies Inc.
Form 10-K for the fiscal year ended December
31, 2008 and Form 10-Q for the period ended March 31, 2009
When the audit fieldwork was conducted,
including the planning stage,
How the auditors got comfortable
auditing the discontinued operations adjustment related to the prior
period
Question 2.
Question 3.
Question 4.
Replace Company with registrant.
Question 5.
We will incorporate your comments in our future filings.
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If you have any questions or concerns related to any of these items please let us know.
We understand that the Company is responsible for the adequacy and accuracy of the disclosure in our filings with the SEC. We also understand that staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing. Further, we understand that 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.
We appreciate the staffs comments and request that the staff contact the undersigned at (949) 752- 7700 with any questions regarding this letter.
Very truly yours, | |
/s/ Hyung Soon Lee | |
Hyung Soon Lee, President | |
Lexon Technologies, Inc. |
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