-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, Tnl8DAfN0KjFQSbWWnXgtuLSlMvNRwJngtKaMDAWyeVUZrT0oh74ehpxy1wWXtcM hN4xmNGVBfv1BfLJkqiI+Q== 0000000000-07-004892.txt : 20070320 0000000000-07-004892.hdr.sgml : 20070320 20070130143828 ACCESSION NUMBER: 0000000000-07-004892 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20070130 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: PPOL INC CENTRAL INDEX KEY: 0001202507 STANDARD INDUSTRIAL CLASSIFICATION: TELEPHONE & TELEGRAPH APPARATUS [3661] IRS NUMBER: 954436774 STATE OF INCORPORATION: CA FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 11661 SAN VICENTE BOULEVARD, #901 CITY: LOS ANGELES STATE: CA ZIP: 90049 BUSINESS PHONE: 310-979-8513 MAIL ADDRESS: STREET 1: 11661 SAN VICENTE BOULEVARD, #901 CITY: LOS ANGELES STATE: CA ZIP: 90049 PUBLIC REFERENCE ACCESSION NUMBER: 0001019687-05-001088 LETTER 1 filename1.txt April 25, 2005 Via Facsimile at 310-979-8519 and U.S. Mail Richard H. Izumi Chief Financial Officer and Secretary PPOL, Inc. 11661 San Vicente Blvd., Suite 901 Suite 901 Los Angeles, CA 90049 Re: PPOL, Inc. Information Statement Pursuant to Section 14(f) of the Securities Exchange Act of 1934 and Rule 14f-1 thereunder Filed April 19, 2005 File Number 5-78970 Dear Mr. Izumi: We have the following comments on your filing. Security Ownership of Certain Beneficial Owners and New Management 1. We note that one of your shareholders, Leo Global Fund, beneficially owns greater than 5% of your common stock. Our records indicate, however, that Leo Global Fund has not filed beneficial ownership reports on Schedule 13D or 13G pursuant to Sections 13(d) and 13(g) of the Exchange Act of 1934 and Rule 13d-1 with regard to this ownership. Please advise. New Directors and Executive Officers 2. In future filings with the Commission, please ensure that the biographical information of the directors and executive officers of the company complies with Item 401 of Regulation S-B. For example, you should revise each new director`s biography to completely describe his business experience for the past five years, disclosing the dates of experience by month and year. Form 8-K Filed on April 4, 2005 3. We note that this document was filed pursuant to Items 1.01, 5.01 and 5.02 of Form 8-K. In light of the disposition of certain assets of the issuer, it would appear that Item 2.01 and, therefore, Item 9.01 to Form 8-K are also applicable to this change of control transaction. Please revise to file an amended Form 8-K reflecting these additional items and the related disclosure, or tell us why you believe those items are not applicable to this transaction. Closing comment We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, 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 in the filings reviewed by the staff 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. 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 filing or in response to our comments on your filing. - ------ Please respond to these comments by promptly amending the filing and submitting a response letter filed via EDGAR and "tagged" as correspondence. If the information you provide in response to our comments materially changes the information that you have already provided to security holders, disseminate the revised materials in a manner reasonably calculated to inform them of the new information. If you do not agree with a comment, please tell us why in your response. Please direct any questions regarding our comments to me at (202) 551-3264. You may also reach me via facsimile at (202) 772- 9203. Sincerely, Mara L. Ransom Special Counsel Office of Mergers and Acquisitions April 25, 2005 Page 1 of 2 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0303 DIVISION OF CORPORATION FINANCE -----END PRIVACY-ENHANCED MESSAGE-----