0001354488-12-002871.txt : 20120629 0001354488-12-002871.hdr.sgml : 20120629 20120523141637 ACCESSION NUMBER: 0001354488-12-002871 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120523 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VIEW SYSTEMS INC CENTRAL INDEX KEY: 0001075857 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-MISCELLANEOUS BUSINESS SERVICES [7380] IRS NUMBER: 592928366 STATE OF INCORPORATION: NV FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1550 CATON CENTER DRIVE STREET 2: SUITE E CITY: BALTIMORE STATE: MD ZIP: 21227 BUSINESS PHONE: 410-242-8439 MAIL ADDRESS: STREET 1: 1550 CATON CENTER DRIVE STREET 2: SUITE E CITY: BALTIMORE STATE: MD ZIP: 21227 CORRESP 1 filename1.htm vsym_corresp.htm
VIEW SYSTEMS, INC.

June 2, 2009



Mr. Robert S. Littlepage
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re:          View Systems, Inc.
Item 4.01 Form 8-K
Filed April 11, 2012
File No. 0-30178

Dear Mr. Littlepage:

Thank you for your comment letter dated April 13, 2012.  The following are View Systems, Inc.’s (the “Company,” “we”, or “our”) responses to your comments.  We are filing Form 8-K/A at the same time that this letter is being filed.

Our response below reflects the changes made in the amendment to comply with Staff’s comment letter.

Form 8-K
Item 4.01

Item 304(a)(1)(ii) of Regulation S-K requires a statement whether the
accountant's report on the financial statements for either of the past two years
contained an adverse opinion or a disclaimer of opinion or was qualified or
modified as to uncertainty, audit scope or accounting principles; and a description
of the nature of each such adverse opinion, disclaimer of opinion, modification or
qualification. Please revise your Form 8-K to include this statement and a
description of the going concern opinion contained in the accountant’s report of
the fiscal years ended December 31, 2010 and 2009 as disclosed in your Form 10-
K.
 
Response:

We have revised Item 4.01(a) as follows:

(ii) Robert L. White & Associates, Inc.’s accountant’s report on the financial statements for the years ended December 31, 2009 and 2010 did not contain an adverse opinion or a disclaimer of opinion, nor were its reports qualified or modified as to uncertainty, audit scope, or accounting principles, but with the exception that, in its reports on the Company’s financial statements for the years ended December 31, 2009 and December 31, 2010, Robert L. White & Associates, Inc. reported that the Company’s financial statements have been prepared assuming that the Company will continue as a going concern.  As the certifying accountant’s opinion pertained to the years ended December 31, 2009 and 2010, the reason for this opinion was that the Company has an accumulated deficit of $22,837,787 at December 31, 2010. Additionally, for the year ended December 31, 2010, the Company had a net loss of $513,353. In the opinion of Robert L. White & Associates, Inc., these conditions raise substantial doubt about the Company’s ability to continue as a going concern.

We also have furnished an updated letter from our former accountant addressing our amended Form 8-K as an exhibit to the amendment.

The Company acknowledges 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 proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,

/s Gunther Than
Gunther Than
President