-----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, AQJ5BA4x4cPQkwKasd4zIPVZXFcgUA18mn4Vf36HzcAU5k5LUJIjfZNdoB/PHuyW 7/I28MUfF2dlzcP9k36kfQ== 0001104659-06-082877.txt : 20070205 0001104659-06-082877.hdr.sgml : 20070205 20061220160454 ACCESSION NUMBER: 0001104659-06-082877 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20061220 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Harbor Acquisition Corp. CENTRAL INDEX KEY: 0001331945 STANDARD INDUSTRIAL CLASSIFICATION: BLANK CHECKS [6770] IRS NUMBER: 562518836 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE BOSTON PLACE STREET 2: SUITE 3630 CITY: BOSTON STATE: MA ZIP: 02108 BUSINESS PHONE: 617-624-8409 MAIL ADDRESS: STREET 1: ONE BOSTON PLACE STREET 2: SUITE 3630 CITY: BOSTON STATE: MA ZIP: 02108 CORRESP 1 filename1.htm

 

H a r b o r    A c q u i s i t i o n    C o r p o r a t i o n

ONE BOSTON PLACE
SUITE 3630
BOSTON, MA 02138

PHONE: (617) 624-8409
FAX: (617) 624-8416

December 20, 2006

Sondra L. Stokes, Associate
    Chief Accountant
Office of the Chief Accountant
United States Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549

 

Re:                           Harbor Acquisition Corporation (the “Company”)
File. No.: 001- 32688

Dear Ms. Stokes:

This letter responds to our telephone conversation on December 5, 2006.   Our conversation related to a letter from the Office of the Chief Accountant, U.S. Securities and Exchange Commission, to the Company dated September 13, 2006 and a written reply from the Company dated November 14, 2006.   As you requested, the November 14 letter is being filed along with this correspondence via EDGAR.

The Company acknowledges that pursuant to SEC rules, companies that have issued warrants which are registered under the Securities Act of 1933, as amended, must deliver registered shares of common stock upon exercise of such warrants.   Nonetheless, the Company believes that its accounting for its outstanding warrants as equity is correct.

The Company also acknowledges the following:

·              the Company is responsible for the adequacy and accuracy of the disclosure in its filing with the Securities and Exchange Commission;

·              staff comments or changes to disclosure in responses to staff comments do not foreclose the Commission from taking any action with respect to a 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

Please contact me if you have any questions relating to the matters discussed in this letter.



Sondra L. Stokes, Associate
   Chief Accountant
December 13, 2006
Page 2

 

I appreciate your assistance with this matter.

 

Very truly yours,

 

 

 

 

 

/s/ Todd A. Fitzpatrick

 

 

Todd A. Fitzpatrick

 

 

Vice President and Chief Accounting

 

 

Officer

 


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